Finding Text
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.