Finding 573545 (2023-003)

Significant Deficiency Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2023
Accepted
2025-08-14
Audit: 364284

AI Summary

  • Core Issue: The Organization lacks effective internal controls over Federal Awards, leading to noncompliance with CFR 200.303.
  • Impacted Requirements: Missing approvals, incorrect reimbursement rates, and payroll discrepancies violate Federal guidelines.
  • Recommended Follow-Up: Implement stronger internal controls to ensure compliance with Federal statutes and maintain proper documentation for all transactions.

Finding Text

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 4 of the 50 transactions selected for testing did not include evidence of approval. 2. 3 of the 50 transactions selected for testing were reimbursed to employees at incorrect rates. 3. 2 of the 27 payroll transactions selected for testing were paychecks to employees at the incorrect rate. 4. 4 of the 4 payroll periods Payroll testing, noted in each of the 4 pay periods selected for testing the hours allocated per time sheets did not tie to the GL Cause of Condition The Organization’s internal controls are not properly designed to be in line with Federal guidelines, particularly, CFR 200.303. Repeat Finding Yes. Effect of Conditions The Organization used Federal Awards for expenditures without proper supporting documentation and without obtaining and maintaining adequate approvals. Recommendation We recommend the Organization establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Organization is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award.

Corrective Action Plan

Management Response and Planned Corrective Action: We partially concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures. Views of Responsible Officials and Corrective Actions: The management team of the Council of Western State Foresters believe in the values of transparency, justification, and documentation for transactions made in the course of conducting job related duties. As a small organization with limited staff, suggested reasonable improvements to processes are always welcome. It is in this spirit that the below corrective actions for the compliance issues noted in the findings from the 2023 audit are put forward. 2023-003 #1 Corrective Action Plan: Documentation and Authorization of Transactions Management acknowledges the findings related to incomplete documentation and approvals for certain per diem and small purchase transactions. While pre-travel authorization forms and signed confirmations were completed by the Executive Director and Pacific Island members, the supporting documentation was not consistently attached to the financial records. Specifically, documentation of approval for the $300 per diem (cash and check) was provided, however the $3.25 ATM fee authorization was not explicitly documented. It is important to note that cash transactions may be necessary due to limited banking infrastructure in certain Pacific Island regions. Additionally, the $130.65 in meeting supplies purchased by the Executive Director was within the organization’s policy threshold for small purchases; however, the specific use of the card by the Executive Director under this policy was not specifically noted for this transaction. A $555.96 transaction was verbally approved by the former Executive Director, but the approval was not documented in accordance with procedures adopted following the previous audit. Staff will consistently attach all supporting documentation for transactions, including email approvals, pre-travel forms, invoice signatures, and system approvals, in accordance with updated reimbursement policies. Policies will be revised to explicitly outline the documentation requirements for per diem transactions involving Pacific Island members, and to clarify the procedures for Executive Director small purchase authorizations. Implementation of a new electronic payment approval system, which will embed approval documentation directly into the system and improve recordkeeping. Once in place, policies and procedures will be updated to reflect this process and address the use of organizational vs. staff charge cards under the new system. 2023-003 #2 Corrective Action Plan: Reimbursement Rates Council of Western State Foresters staff and Balance Financial Management will review and validate reimbursement rates to ensure alignment with current policies and applicable guidance going forward. 2023-003 #3 Corrective Action Plan: Salary Allocations and Time Reporting Management acknowledges the observation. As employees are salaried, some variation in the conversion of salary dollars to hours is expected. Nevertheless, management remains committed to ensuring that cost allocations are reasonable, consistent, and well-documented. 2023-003 #4 Corrective Action Plan: Grant Time Allocation The process for allocating staff time to specific grants has been updated to improve accuracy and compliance. Staff now allocate time directly based on hours worked per grant, and supporting documentation is available upon request to substantiate these allocations. Anticipated Completion: All internal control items have been completed, and implementation of the new electronic payment system is in process with an estimated completion date of August 2025.

Categories

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 573546 2023-003
    Significant Deficiency Repeat
  • 573547 2023-003
    Significant Deficiency Repeat
  • 573548 2023-003
    Significant Deficiency Repeat
  • 573549 2023-003
    Significant Deficiency Repeat
  • 573550 2023-003
    Significant Deficiency Repeat
  • 573551 2023-004
    Significant Deficiency
  • 573552 2023-004
    Significant Deficiency
  • 573553 2023-004
    Significant Deficiency
  • 573554 2023-004
    Significant Deficiency
  • 573555 2023-004
    Significant Deficiency
  • 573556 2023-004
    Significant Deficiency
  • 573557 2023-005
    Significant Deficiency
  • 573558 2023-005
    Significant Deficiency
  • 573559 2023-005
    Significant Deficiency
  • 573560 2023-005
    Significant Deficiency
  • 573561 2023-005
    Significant Deficiency
  • 573562 2023-005
    Significant Deficiency
  • 1149987 2023-003
    Significant Deficiency Repeat
  • 1149988 2023-003
    Significant Deficiency Repeat
  • 1149989 2023-003
    Significant Deficiency Repeat
  • 1149990 2023-003
    Significant Deficiency Repeat
  • 1149991 2023-003
    Significant Deficiency Repeat
  • 1149992 2023-003
    Significant Deficiency Repeat
  • 1149993 2023-004
    Significant Deficiency
  • 1149994 2023-004
    Significant Deficiency
  • 1149995 2023-004
    Significant Deficiency
  • 1149996 2023-004
    Significant Deficiency
  • 1149997 2023-004
    Significant Deficiency
  • 1149998 2023-004
    Significant Deficiency
  • 1149999 2023-005
    Significant Deficiency
  • 1150000 2023-005
    Significant Deficiency
  • 1150001 2023-005
    Significant Deficiency
  • 1150002 2023-005
    Significant Deficiency
  • 1150003 2023-005
    Significant Deficiency
  • 1150004 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.720 Community Wildlife Defense Program $127,066
10.664 Cooperative Forestry Assistance $107,763
10.698 State & Private Forestry Cooperative Fire Assistance $70,732
10.676 Forest Legacy Program $519