Finding 575326 (2024-002)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2024
Accepted
2025-09-02
Audit: 365374
Organization: Shiloh Home Inc. (CO)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance, specifically a lack of documented review and approval for expenditures.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and 2 CFR 200.403(g) is at risk due to inadequate documentation of expenditure reviews.
  • Recommended Follow-Up: Implement policies to ensure all expenditures are reviewed and approved by an official, with proper documentation like signatures or electronic approvals.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.623 Federal Program Titles: Basic Center Grant Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal controls over federal awards. Furthermore, 2 CFR 200.403(g) requires that costs be adequately documented in order to be allowable under federal awards. Condition: During our testing of expenditures charged to the major program, we noted multiple instances that did not contain documented evidence of review or approval by a supervisor or program manager. Questioned Costs: None. Context: During our testing of ten expenditures charged to the major program, we noted three instances that did not contain documented evidence of review or approval by a supervisor or program manager. Although management stated that expenditures are reviewed before processing, no signatures, initials, timestamps, or electronic workflow logs were retained to demonstrate the review occurred. Effect: Failure to document review and approval increases the risk that unallowable or erroneous expenditures could be charged to the federal award and go undetected. Although no unallowable costs were identified in our testing, the control deficiency could lead to future noncompliance or questioned costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization enforce policies requiring all expenditures charged to federal programs to be reviewed and approved by an appropriate official, and document the approval through dated signatures, electronic approvals, or maintained audit trails in software utilized by the Organization. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Corrective Action Plan: Shiloh will expand its recurring processes around the disbursement of funds under its federal awards to ensure there is documentation that the associated expenses are allowable. Shiloh will also revisit its relationship with Spark Community Foundation who are currently engaged to perform the review and approval determination, including for Shiloh specific charges.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 575324 2024-001
    Significant Deficiency Repeat
  • 575325 2024-001
    Significant Deficiency Repeat
  • 575327 2024-003
    Significant Deficiency
  • 1151766 2024-001
    Significant Deficiency Repeat
  • 1151767 2024-001
    Significant Deficiency Repeat
  • 1151768 2024-002
    Significant Deficiency
  • 1151769 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $501,987
84.425 Education Stabilization Fund $415,304
93.623 Basic Center Grant $260,415
93.557 Education and Prevention Grants to Reduce Sexual Abuse of Runaway, Homeless and Street Youth $176,363
93.550 Transitional Living for Homeless Youth $170,953
94.013 Americorps Volunteers in Service to America 94.013 $25,879
93.670 Child Abuse and Neglect Discretionary Activities $17,661