Finding Text
Internal Control Over Compliance
Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323.
Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties.
Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures.
Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis.
Questioned Cost: None
Repeat Finding: Yes
Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement.
Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties.
Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given to the Deputy Director, Lucas Ashby for review. (current procedure). Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager, Jon Greenwalt (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented]
Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.