Finding Text
2024-003 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance and Noncompliance – Appropriate Internal Control Structure Related to Compliance Requirements
A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and C. Cash Management
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place.
Condition and Context: Throughout the entirety of 2024 the Organization did not have the written policies in place in accordance with §200.302 Financial Management paragraph (b)(6) and (b)(7), which requires written procedures for policies on drawing federal funds and written policies for determining the allowability of costs in accordance with Subpart E of the Uniform Guidance and the terms and conditions of the federal award.
This is a repeat finding of 2023-001.
Cause and Effect: As the policies referenced above are not written, the Organization is not in compliance with the requirements. In addition, lack of written policies related to federal awards may lead to noncompliance with other federal requirements and the terms and conditions of federal awards.
Recommendation: We recommend the policies in accordance with §200.302 Financial Management paragraph (b)(6) and (b)(7) be written by the Organization, approved by the Board of Directors, and included in the permanent files of the Organization.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation, and updated our policies in accordance with §200.302 Financial Management paragraph (b)(7) in December 2024 and will update our policies in accordance with (b)(6) by August 2025.