Finding 524378 (2023-002)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2025-02-24

AI Summary

  • Core Issue: Inadequate internal controls led to incorrect year-end account reconciliations, causing significant adjustments to financial statements.
  • Impacted Requirements: Compliance with 2 CFR 200.303 is lacking, risking reporting errors and potential misappropriation of funds.
  • Recommended Follow-Up: Implement monthly reconciliations for all asset and liability accounts, with thorough reviews and documentation of discrepancies.

Finding Text

Finding 2023-002: Account Reconciliations and Financial Statement Close Process (Significant Deficiency) Federal Programs: All Federal programs Criteria: Under 2 CFR 200.303, Internal Controls, the Uniform Guidance requires that the grantee must: establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The year-end schedules supporting certain asset and liability accounts were incorrectly prepared and required revision, resulting in adjustments to ICMEC's consolidated financial statements. In addition, the intercompany assets and liabilities were not reconciled. Due to the above, a significant amount of time was spent by management during the audit process reconciling various accounts which resulted in audit delays. The audit delays, in turn, resulted in additional audit work performed after the original end date of field work. Cause: ICMEC's controls are not adequately designed to ensure timely and accurate reconciliation of asset and liability accounts, including the intercompany assets and liabilities. As a result, significant adjustments were proposed by management and the auditors during the audit. Effect: Without the proper reconciliation of all accounts on a monthly basis, in a timely manner, as well as the proper review and approval of such reconciliations, there exists the potential for reporting errors and misappropriation of funds. Additionally, as a result of these delays, ICMEC did not submit its Data Collection Form in time to be in compliance with the due date of September 30, 2024. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on various asset, liability, support and revenue and expense account balances. We consider our sample and testing to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all asset and liability account reconciliations, including intercompany assets and liabilities, be performed on a monthly or quarterly (at a minimum) basis. We also recommend detailed reviews and approvals of all supporting schedules (and related consolidated financial statements) be performed and contemporaneously documented in the accounting records. Any discrepancies or other issues should be resolved in a timely manner.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: Monthly reconciliations were not being done throughout 2023. The 2022 Audit that identified the need for such a process was not completed until February 2024. ICMEC does not prepare a consolidated financial statement or reconcile intercompany accounts. Essentially the issue is that balance sheet schedules were not maintained from month to month during the year. However, we did provide the auditors with reconciled schedules at year end. Additionally, ICMEC did not historically keep a consolidated (including the Australian affiliate) financial statement via its accounting system, so all Australia affiliate activity was added manually during the audit. Action plan: we began maintaining regular monthly balance sheet schedules for all accounts in June 2024. Furthermore, the Australian affiliate was deconsolidated as of July 6, 2023 so ICMEC no longer needs to maintain the activity of the Australian affiliate in the consolidated financial statements.

Categories

Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524379 2023-003
    Material Weakness
  • 524380 2023-002
    Significant Deficiency
  • 524381 2023-003
    Material Weakness
  • 524382 2023-002
    Significant Deficiency
  • 524383 2023-003
    Material Weakness
  • 1100820 2023-002
    Significant Deficiency
  • 1100821 2023-003
    Material Weakness
  • 1100822 2023-002
    Significant Deficiency
  • 1100823 2023-003
    Material Weakness
  • 1100824 2023-002
    Significant Deficiency
  • 1100825 2023-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
19.019 International Programs to Combat Human Trafficking $1.16M
19.023 Overseas Schools Program $168,383
19.703 Criminal Justice Systems $32,449