Finding 560138 (2022-013)

Material Weakness
Requirement
ABH
Questioned Costs
-
Year
2022
Accepted
2025-05-13
Audit: 356132
Organization: Oregon Coast Community Action (AL)

AI Summary

  • Core Issue: Missing documentation for approval of disbursements raises concerns about compliance with federal regulations.
  • Impacted Requirements: Internal controls over federal awards must ensure proper approval and documentation as per 2 CFR 200.303.
  • Recommended Follow-up: Establish a process to prepare, review, and retain documentation for allowable costs and approvals to ensure compliance.

Finding Text

Activities Allowed/Allowable Costs/Costs Principles, Period of Performance Emergency Rental Assistance ALN# 21.023 US Department of the Treasury Passed through Oregon Housing and Community Services Federal Grant/Contract Number: ERA000 Grant period – 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish 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 – In our sample of 100 items, we noted the following exceptions: • 13 instances where the check request used to identify approval of the disbursement could not be located • 1 instance where the request was not signed by the supervisor Cause – Supporting check request documentation relevant to verify that proper approval controls had been performed could not be obtained. Effect – Expenses not relevant to the fund or client benefits could be paid without approval. Expenses could be in excess of costs that client was eligible for or could be outside of the period of performance. Questioned Costs – Not applicable. Recommendation – Documentation should be prepared, reviewed, and retained to support the allowable costs, activities allowed, eligibility, and period of performance for benefits paid to individuals for services. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.

Corrective Action Plan

ORCCA's current process at the program level has improved to ensure proper documentation of eligibility. The Housing director and staff have implemented this internal control at the program level. The finance department's internal control (as noted earlier) is in place to ensure the payment requests have sufficient supporting documentation. As for record retention, ORCCA hired additional temp workers to ensure completed transactions are filed timely with the goal of going paperless in the near future. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

Categories

Allowable Costs / Cost Principles Eligibility Period of Performance Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 560113 2022-008
    Material Weakness
  • 560114 2022-008
    Material Weakness
  • 560115 2022-008
    Material Weakness
  • 560116 2022-008
    Material Weakness
  • 560117 2022-008
    Material Weakness
  • 560118 2022-008
    Material Weakness
  • 560119 2022-009
    Material Weakness
  • 560120 2022-009
    Material Weakness
  • 560121 2022-009
    Material Weakness
  • 560122 2022-009
    Material Weakness
  • 560123 2022-009
    Material Weakness
  • 560124 2022-009
    Material Weakness
  • 560125 2022-010
    Significant Deficiency
  • 560126 2022-010
    Significant Deficiency
  • 560127 2022-010
    Significant Deficiency
  • 560128 2022-010
    Significant Deficiency
  • 560129 2022-010
    Significant Deficiency
  • 560130 2022-010
    Significant Deficiency
  • 560131 2022-011
    Significant Deficiency
  • 560132 2022-011
    Significant Deficiency
  • 560133 2022-011
    Significant Deficiency
  • 560134 2022-011
    Significant Deficiency
  • 560135 2022-011
    Significant Deficiency
  • 560136 2022-011
    Significant Deficiency
  • 560137 2022-012
    Material Weakness
  • 560139 2022-014
    Material Weakness
  • 560140 2022-014
    Material Weakness
  • 560141 2022-014
    Material Weakness
  • 560142 2022-014
    Material Weakness
  • 560143 2022-014
    Material Weakness
  • 560144 2022-015
    Material Weakness
  • 560145 2022-015
    Material Weakness
  • 560146 2022-015
    Material Weakness
  • 560147 2022-015
    Material Weakness
  • 560148 2022-015
    Material Weakness
  • 560149 2022-016
    Material Weakness
  • 560150 2022-016
    Material Weakness
  • 560151 2022-016
    Material Weakness
  • 560152 2022-016
    Material Weakness
  • 560153 2022-016
    Material Weakness
  • 1136555 2022-008
    Material Weakness
  • 1136556 2022-008
    Material Weakness
  • 1136557 2022-008
    Material Weakness
  • 1136558 2022-008
    Material Weakness
  • 1136559 2022-008
    Material Weakness
  • 1136560 2022-008
    Material Weakness
  • 1136561 2022-009
    Material Weakness
  • 1136562 2022-009
    Material Weakness
  • 1136563 2022-009
    Material Weakness
  • 1136564 2022-009
    Material Weakness
  • 1136565 2022-009
    Material Weakness
  • 1136566 2022-009
    Material Weakness
  • 1136567 2022-010
    Significant Deficiency
  • 1136568 2022-010
    Significant Deficiency
  • 1136569 2022-010
    Significant Deficiency
  • 1136570 2022-010
    Significant Deficiency
  • 1136571 2022-010
    Significant Deficiency
  • 1136572 2022-010
    Significant Deficiency
  • 1136573 2022-011
    Significant Deficiency
  • 1136574 2022-011
    Significant Deficiency
  • 1136575 2022-011
    Significant Deficiency
  • 1136576 2022-011
    Significant Deficiency
  • 1136577 2022-011
    Significant Deficiency
  • 1136578 2022-011
    Significant Deficiency
  • 1136579 2022-012
    Material Weakness
  • 1136580 2022-013
    Material Weakness
  • 1136581 2022-014
    Material Weakness
  • 1136582 2022-014
    Material Weakness
  • 1136583 2022-014
    Material Weakness
  • 1136584 2022-014
    Material Weakness
  • 1136585 2022-014
    Material Weakness
  • 1136586 2022-015
    Material Weakness
  • 1136587 2022-015
    Material Weakness
  • 1136588 2022-015
    Material Weakness
  • 1136589 2022-015
    Material Weakness
  • 1136590 2022-015
    Material Weakness
  • 1136591 2022-016
    Material Weakness
  • 1136592 2022-016
    Material Weakness
  • 1136593 2022-016
    Material Weakness
  • 1136594 2022-016
    Material Weakness
  • 1136595 2022-016
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $3.14M
21.023 Covid-19 Emergency Rental Assistance Program $1.97M
64.033 Va Supportive Services for Veteran Families Program $651,180
93.568 Covid-19 Low-Income Home Energy Assistance $637,444
10.569 Emergency Food Assistance Program (food Commodities) $595,963
93.575 Child Care and Development Block Grant $393,586
93.575 Baby Promise-Child Care and Development Block Grant $289,596
14.231 Covid-19 Emergency Solutions Grant Program $181,018
10.558 Child and Adult Care Food Program $173,829
93.600 Covid-19 Head Start $127,071
14.239 Home Investment Partnerships Program $98,539
93.568 Covid-19low-Income Home Energy Assistance $87,568
14.231 Emergency Solutions Grant Program $69,570
16.575 Crime Victim Assistance $63,673
14.267 Continuum of Care Program $61,999
93.568 Low-Income Home Energy Assistance $60,503
81.999 Weatherization Assistance for Low-Income Persons (bpa Funds) $45,793
10.568 Emergency Food Assistance Program (administrative Costs) $42,093
97.024 Emergency Food and Shelter National Board Program $12,430
93.556 Marylee Allen Promoting Safe and Stable Families Program $11,344
81.042 Weatherization Assistance for Low-Income Persons (doe Funds) $7,896
93.558 Temporary Assistance for Needy Families $4,796
64.033 Va Supportive Services for Veteran Families Program - Shallow Subsidiary Program $1,587