Finding 547120 (2023-002)

Significant Deficiency
Requirement
BCG
Questioned Costs
-
Year
2023
Accepted
2025-03-31

AI Summary

  • Core Issue: The organization lacks proper segregation of duties in preparing and reviewing monthly NIST schedules, increasing the risk of errors and noncompliance.
  • Impacted Requirements: Internal controls must ensure duties are separated, and cash management procedures need to be updated per 2 CFR Part 200.305.
  • Recommended Follow-Up: Implement a review process by an independent individual for drawdown requests and update the cash management policy to align with current staffing and procedures.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 11.611, United States Department of Commerce (DOC), National Institute of Standards and Technology (NIST) Federal Award Identification Number and Year - 70NANB20H067 Finding Type - Significant deficiency Repeat Finding - No Criteria - Internal controls should be put in place to ensure grant duties are appropriately segregated between preparation and review processes. In addition, written procdures to implement cash management requirements should in place and updated in accordance with 2 CFR Part 200.305. Condition - The Organization did not have appropriate segregation of duties surrounding the preparation and review of the monthly NIST schedules which accumulate the information necessary to calculate allowable costs and matching for drawdown requests. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Questioned Costs - Not applicable Context - One individual was responsible for the preparation of the monthly schedule described above and submission of the drawdown request. The cash management policy was not updated when there was restructuring in the finance department during fiscal year. Cause and Effect - Turnover within the finance department contibuted to the lack of segregation of duties and delay in updating the cash management policy. A lack of segregation of duties allows for the potential for errors and/or noncompliance to occur without detection. The outdated cash management policy was not reflective of the actual process. Recommendation - An individual independent of the preparation process should review and approve the information used to calculate allowable costs and matching prior to submitting the drawdown requests for cash management. Additionally, the cash management policy should be updated to reflect the new process. Views of Responsible Officials and Planned Corrective Actions - Subsequent to year end, the reorganized finance team put new controls and procedures in place. Moving forward the Accounting Supervisor will calculate the NIST MEP monthly program income which is used to determine the monthly award drawdown of cash from the available grant award funds. This is reviewed by the Controller and this report is used to create SF 425.

Corrective Action Plan

Condition: The Organization did not have appropriate segregation of duties surrounding the preparation and review of the monthly NIST schedules which accumulate the information necessary to calculate allowable costs and matching for drawdown requests. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Action: Subsequent to year end, the reorganized finance team put new controls and procedures in place. Moving forward the Accounting Supervisor will calculate the NIST MEP monthly program income which is used to determine the monthly award drawdown of cash from the available grant award funds. This is reviewed by the Controller and this report is used to create SF-425. Contact person responsible for corrective action: Alan Kowalewski, Controller Anticipated Completion Date: 07/01/24

Categories

Cash Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting Significant Deficiency Matching / Level of Effort / Earmarking Program Income

Other Findings in this Audit

  • 547119 2023-001
    Material Weakness
  • 547121 2023-003
    Significant Deficiency
  • 1123561 2023-001
    Material Weakness
  • 1123562 2023-002
    Significant Deficiency
  • 1123563 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
12.600 Community Investment Defense Manufacturing Community Support Program $30,380
11.611 Manufacturing Extension Partnership $30,000
17.278 Covid-19 - Wioa Dislocated Worker Formula Grants $2,405