Finding 567052 (2024-001)

Material Weakness
Requirement
ABH
Questioned Costs
-
Year
2024
Accepted
2025-06-25

AI Summary

  • Core Issue: Payroll expenses charged to FEMA lacked proper review and approval of employee timecards.
  • Impacted Requirements: Internal controls under Section 200.303 of the Uniform Guidance were not established, risking non-compliance with federal regulations.
  • Recommended Follow-Up: CFNI should implement a policy for timely review and approval of all timecards for federal programs, along with regular audits to ensure compliance.

Finding Text

Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Identification of the federal program: Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Indiana Department of Homeland Security Pass-Through Award Period: 03/01/2020–05/11/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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: Payroll expenses charged to FEMA that related to timecards for employees were not reviewed and approved. Cause: Community Foundation of Northwest Indiana, Inc. and Subsidiaries (CFNI) does not have internal controls in place that require all timecards for employees submitted to a federal program to be reviewed and approved.   Effect or potential effect: Expenses may be charged to the federal award that are not in compliance with the federal or pass-through grant agreement. Questioned costs: None. Context: For three (totaling $1,756) of 40 (totaling $27,583) (8%) payroll transactions sampled during the fiscal year, the employees’ timecards did not have evidence of review and approval by the employees’ manager. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: CFNI should implement internal controls to require the review and approval of all timecards charged to a program funded with federal funds. Views of responsible officials: CFNI acknowledges the finding related to the lack of documented review and approval of all timecards for payroll expenses charged to federally funded programs. In line with industry standards, CFNI prioritizes timely payroll processing and does not delay payroll for outstanding timecard approvals. While this is not a recurring issue and did not result in any questioned costs, CFNI recognizes the importance of ensuring compliance with all federal requirements. To address this finding and prevent recurrence, CFNI is implementing a comprehensive policy that mandates timely review and approval of all timecards associated with payroll expenses charged to federal grants. Additionally, CFNI is establishing a formal process to monitor adherence to this policy, including regular audits and detailed documentation of the review process.

Corrective Action Plan

Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Federal Grantor: United States Department of Homeland Security Assistance Listing No.: Assistance Listing 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Indiana Department of Homeland Security Federal Award Period of Performance: March 1, 2020 – May 11, 2023 A material weakness was identified related to internal controls over payroll expenses charged to FEMA funds, subject to the Uniform Guidance (UG) audit. This guidance requires internal controls to comply with the terms of the federal award as well as with the "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 COSO. The finding was a compliance matter and did not result in any questioned costs. Community Foundation of Northwest Indiana, Inc. and Subsidiaries (CFNI) acknowledges the finding related to the lack of documented review and approval of all timecards for payroll expenses charged to federally funded programs. In line with industry standards, CFNI prioritizes timely payroll processing and does not delay payroll for outstanding timecard approvals. While this is not a recurring issue and did not result in any questioned costs, CFNI recognizes the importance of ensuring compliance with all federal requirements. To address this finding and prevent recurrence, CFNI is implementing a comprehensive policy that mandates timely review and approval of all timecards associated with payroll expenses charged to federal grants. Additionally, CFNI is establishing a formal process to monitor adherence to this policy, including regular audits and detailed documentation of the review process. CFNI is committed to strengthening internal controls, improving oversight, and ensuring full compliance with federal grant requirements. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

Categories

Allowable Costs / Cost Principles Period of Performance Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 567053 2024-002
    Material Weakness
  • 1143494 2024-001
    Material Weakness
  • 1143495 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.493 Congressional Directives $1.44M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $900,175