Finding 576167 (2024-001)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-09-11
Audit: 366081
Organization: Wtia Workforce Institute (WA)
Auditor: Clark Nuber Ps

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance with allowable costs, specifically regarding the lack of documented approvals for nonpayroll disbursements.
  • Impacted Requirements: Compliance with 2 CFR Part 200 and organizational policy requiring documented approval for all nonpayroll disbursements.
  • Recommended Follow-Up: Strengthen procedures to ensure proper retention and migration of documentation during system changes, and ensure all disbursements are approved as per policy.

Finding Text

Finding - 2024-001 Significant deficiency in internal control over compliance with allowable costs meeting the requirements of 2 CFR Part 200. Federal Agency: U.S. Department of Commerce Program Title: Economic Adjustment Assistance Program Assistance Listing Number: 11.307 Award Number: MDM9F73QJ1Z1 Criteria Organization policy and Uniform Guidance (2 CFR 200.303) require that all nonpayroll disbursements be supported by documented approval from an authorized official prior to payment to ensure proper internal control over federal funds. Condition/Context During our testing of 21 nonpayroll disbursements, we noted that 9 disbursements lacked evidence of the required approval by an authorized official. Cause During the year, the Organization implemented a new financial system. As a result of the system change, all supporting data for nonpayroll disbursements was lost prior to the conversion and could not be recovered or reconstructed. Effect Failure to document approvals increases the risk of unauthorized or improper disbursements and noncompliance with internal control policies, which could result in questioned costs or loss of federal funding Questioned Costs None identified. Recommendation We recommend the Organization reinforce its procedures and implement controls to ensure that supporting documentation is retained and properly migrated during system changes, and that all nonpayroll disbursements are properly approved and documented in accordance with policy and federal requirements Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Apprenti agrees with the finding and acknowledges the importance of maintaining a full audit trail for all disbursement approvals. Apprenti adhered to its internal controls over compliance with allowable costs in accordance with 2 CFR Part 200 for all nonpayroll expenditures and had no findings in prior Single Audits. However, due to a financial system migration, the audit trail documenting approval workflows for certain transactions was lost and could not be recovered or reconstructed. To prevent similar issues in the future and reinforce compliance, Apprenti has implemented the following corrective action: System Audit Trail Safeguards: Post‐migration, Apprenti implemented robust data retention protocols across both primary and backup financial systems to ensure that all approval workflows are securely preserved and transferable in the event of future system changes or migrations.

Categories

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1152609 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.307 Economic Adjustment Assistance $14.52M