Finding Text
Federal Awards Finding 2023-004: Noncompliance with Federal Award Program Requirements
Criteria or Specific Requirement
The Uniform Guidance states that the auditee is responsible for “maintaining internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.”
Specifically, this Finding applies to the following Compliance Requirements outlined in the 2023 Compliance Supplement:
1. Activities Allowed or Unallowed & Allowable Costs/Cost Principles
2. Procurement, Suspension & Debarment
Finding/Condition
We noted the following deficiencies:
1. The Rancheria was unable to provide supporting documentation for the allocation of expenditures reported for federal award programs.
2. The Rancheria was unable to provide actual time records for employees, supporting payroll expenditures claimed as expenditures for federal award programs.
3. The Rancheria was unable to provide documentation to show that it complied with the procurement standards required in 2 CFR 200.318. Additionally, the Rancheria does not have a procurement policy which complies with those standards.
Context
1. 4 of 31 transactions tested
2. 2 of 31 transactions tested
3. 1 of 31 transactions tested
Effect
The Rancheria has possibly misstated federal expenditures between federal programs.
Cause
The Rancheria has not implemented a grant management system or procurement policy which is in compliances with 2 CFR 200.318.
Recommendation
The Rancheria should implement a grant management system, and also develop a process for capturing the correct allocation of expenditures for programs. Additionally the Rancheria should adopt and implement a new procurement policy.