Finding 565673 (2024-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-06-20
Audit: 359353
Organization: School's Out Washington (WA)
Auditor: Clark Nuber Ps

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to allowable costs for federal awards.
  • Impacted Requirements: Costs must comply with 2 U.S. CFR 200 and GAAP; subscription costs were improperly accounted for.
  • Recommended Follow-Up: SOWA should communicate internal control procedures to staff and strengthen controls over allowable costs.

Finding Text

Significant deficiency in internal controls over compliance related to allowable costs. Federal Agency: Department of Health and Human Services Program Titles: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing Number: 93.566 Award Number: 2134-30265 Award Period: October 1, 2021 - September 30, 2025 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards provides for specific items of cost which are considered to be unallowable. Additionally, costs must be accounted for in accordance with generally accepted accounting principles (GAAP) and be given consistent treatment. SOWA’s internal controls over allowable costs failed to remove these items from allowable costs. Condition/Context During the testing of allowable costs, there were two instances where subscription costs were not accounted for in accordance with GAAP. Subscription costs should be expensed over the performance period versus when paid. Questioned Costs $989 Cause SOWA’s operation of internal controls was not sufficient to ensure that subscription costs charged to federal awards were in accordance with GAAP. Effect Based on the exception noted in the operation of internal controls, unallowable costs could be charged to the Federal Award. Repeat Finding This is not a repeat finding. Recommendation We recommend that SOWA ensures current internal controls are communicated to staff charging expenses to federal awards and consider the need for further strengthening internal controls over allowable costs. Views of Responsible Official of Auditee Management concurs with the finding and has provided accompanying corrective action plan.

Corrective Action Plan

Create a policy that clearly specifies that subscription and other costs related to federally funded programs which are invoiced on an annual basis are expensed on an accrual basis rather than as period expenses. Policy will also include procedures to assure that for federally funded programs the recognition of expenses aligns with the performance period of the federal contracts. Implement new policy effective immediately. Revise treatment of all bills invoiced on an annual basis received in 2025 to comply with new policy. Make adjusting journal entries as needed to assure that any expenses related to annual invoices do not result in charges to federally funded programs beyond the performance period. Anticipated completion date: 6/30/25 School’s Out Washington considers the above steps sufficient and adequate to close the gaps in the coding of transactions that may have permitted unallowable costs to post to grants for YE2024. These steps will remedy the lapse in effectiveness experienced by School’s Out Washington’s internal controls over allowable costs.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1142115 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $5.75M