Finding 509788 (2023-005)

Material Weakness
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-11-22
Audit: 329517
Auditor: Mjco LLC

AI Summary

  • Core Issue: The Organization misused TRIO funds for construction and renovation, violating federal regulations.
  • Impacted Requirements: Federal statutes prohibit charging construction costs to TRIO programs, leading to noncompliance.
  • Recommended Follow-Up: Review grant terms to identify unallowable activities and establish approval procedures for costs charged to the grant.

Finding Text

Internal Control Impact: Material weakness Criteria: The Federal statutes, regulations, and terms and conditions of the TRIO cluster list construction, renovation and remodeling of facilities as unallowable activities. These cost items can never be charged to any TRIO program. Condition: The Organization used TRIO funds to pay for various construction, renovation and remodeling costs during the year ended December 31, 2023. Cause: The Organization had a lack of awareness of the specific activities which were unallowed per the grant award. The Organization also failed to implement adequate internal control activities to review and approve costs being charged to the grant program. Effect: Use of grant funds for unallowable activities resulted in noncompliance and questioned costs. Questioned costs: Known questioned costs identified totaled $14,891. Likely extrapolated questioned costs totaled $21,456 over the remaining population. Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Officials: Management of the Organization concurs with the finding. Please refer to the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to ensure that terms and conditions of state and/or federal grant awards are reviewed by the CFAO and FM to identify unallowable activities. Identification of unallowable activities will be conveyed to all relevant parties. BGCCG management will also work closely with the CFAO and FM to implement procedures for pre-reviewing and pre-approval of all recommended purchases/costs to be charged to state and/or federal grant programs. Acknowledged, Phillip Bryant President & CEO

Categories

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 509784 2023-001
    Material Weakness
  • 509785 2023-002
    Significant Deficiency
  • 509786 2023-003
    Material Weakness
  • 509787 2023-004
    Material Weakness
  • 1086226 2023-001
    Material Weakness
  • 1086227 2023-002
    Significant Deficiency
  • 1086228 2023-003
    Material Weakness
  • 1086229 2023-004
    Material Weakness
  • 1086230 2023-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $563,423
84.044 Trio Talent Search $379,524
93.558 Temporary Assistance for Needy Families $323,807
10.558 Child and Adult Care Food Program $297,857
84.047 Trio Upward Bound $284,663
10.559 Summer Food Service Program for Children $142,761