Finding Text
Identification of the federal program: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Noncompliance and Significant Deficiency in internal controls over reporting
Criteria:
Cooperatives must ensure expenditures are properly allocated to the appropriate grant and not duplicated across multiple funding sources.
Condition:
The Cooperative reported the same $1,190,000 in expenditures under two separate federal grant agreements.
Cause:
The Cooperative lacked adequate internal controls and oversight to ensure compliance with reporting proper grant expenditure. There was also a miscommunication between program and finance staff to the consultant regarding how expenditures were to be reported across grants.
Effect:
Duplicate cost reporting may result in questioned costs, potential disallowance of expenditures, and result in noncompliance with federal grant requirements.
Questioned Costs:
None
Perspective:
Double reimbursement was not a risk in this finding as one submission was being charged against an advance.
Recommendations:
The Cooperative should establish a review process to ensure financial reports are accurate and expenditures are only charged to one funding source.
Views of responsible officials:
Finance will have a dual review process implemented before the submission of expenditure reporting requirements. These expenditures will also be cross-referenced with what projects were submitted for each project via a centralized tracker managed by Finance. Communication of internal roles and responsibilities between finance and the functional teams will be clearly defined, and the Cooperative’s Finance function will be the central single control point of any output submitted to any third-party agency. Finance will document the entirety of these communications.