Finding Text
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.