Finding 571487 (2024-004)

Approval of Allowable Costs (Significant Deficiency) Federal Award #’s: 10.553, 10.555 Child Nutrition Cluster Federal Award Years: Multiple Federal Agencies: US Department of Agriculture Passthrough Agency: Texas State Department of Agriculture Compliance Requirement: Allowable Costs Criteria: According to 2 CFR 200.303 (a) the recipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). Review and approval controls designed to ensure accuracy and adequate segregation of duties are an essential component of effective internal controls over costs. Condition/Context: During our testing we noted 2 out of 9 nonpayroll costs tested, totaling $79,106, were not separately reviewed and approved by the Department Chair and/or Superintendent. The costs were accurate and supported by invoices. However, the review and approval of the costs by someone other than the person entering the payment was not supported. Cause: The Academy did not effectively implement existing procedures for the separate review and approval of costs. Effect: The absence of proper approval increases the risk of unauthorized or inappropriate expenses being paid, which could result in loss of federal grant funding. Recommendation: The Academy implements procedures to ensure the effective implementation of established controls. We recommend that the Academy reinforce the importance of the expense approval process through additional training for relevant staff and reiterate the importance of segregation of duties in this process.