Finding 581950 (2022-001)

2022‐001—FINANCIAL TRACKING OF FEDERAL GRANTS AND PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Federal Agency: All presented in the Schedule of Expenditures of Federal Awards (SEFA). Federal Program Name: All presented in the SEFA. Assistance Listing Number: All presented in SEFA. Federal Award Identification Number and Year: All presented in SEFA. Award Period: N/A Questioned Costs: None Type of Finding • (E) Significant Deficiency in Internal Control Over Compliance of Federal Awards • (F) Instance of Noncompliance related to Federal Awards Statement of Condition During our audit, we were unable to determine if the Schedule of Expenditures of Federal Awards (SEFA) was accurate. While we believe the selection of the NMH200032-2020 and NMH2001W068-2020 grants were accurate as major federal programs per our determination calculation, we did not receive sufficient audit evidence on the accuracy of the expenditures presented in the SEFA. Therefore, we were unable to perform sufficient auditing procedures such as comparing and reconciling such information directly to the underlying accounting and other records used to prepare the financial statements, This has led us to disclaim our opinion related to whether the SEFA is fairly stated, in all material respects, in relation to the financial statements as a whole for the year ended December 31, 2022. Criteria 2 CFR 200.510 indicates that the auditee must prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 200.502 Basis for Determining Federal Awards Expended. Per 2 CFR 200.502 the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program establish and maintain effective internal controls over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards. Effect Without an established process governed by effective internal controls, the Housing Trust may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, the errors could result in improper selections of major federal program(s) for the single audit and a substandard single audit. This could affect the auditee’s eligibility for future federal awards or result in audit findings by the federal awarding agencies or pass-through entities. Cause the Housing Trust did not have adequate policies and procedures to ensure that the information reported in its SEFA was accurate and complete. Also, the Housing Trust did not have a system to reconcile its SEFA with its general ledger and other supporting documents. Recommendation We recommend the Housing Trust improve the financial tracking of its grants, corresponding expenses and other activity related to those federal grants to ensure the information reported in its SEFA is accurate and complete. We also recommend that the auditee establish a system to reconcile its SEFA with its general ledger and other supporting documents, including the name of grantor, the assistance listing #, the pass-through number, if applicable, and review its SEFA for any errors or omissions before submission. View of Responsible Officials and Corrective Action Plan Response. Agreed. Where feasible, the Housing Trust will aim to improve management of all federal grants. A process of documentation verification prior to any requests made for financial draws will include employee, supervisor, business operations manager, and executive director level approvals to ensure compliance and availability of funds. A monthly federal request for reimbursements with all grantee information will be used and reconciled monthly with QuickBooks. This report will mirror the SEFA form so auditors will receive the information in a timely manner. For any quarterly reports, the three months of reporting will again be reconciled prior to submission. All new processes and compliance will be updated in the policies and procedure manual. As the Executive Director prepares the 2024 budget, a reorganization of the business operations department will be sought. A new position to prepare and work on all federal grant tasks will be hired and report to the Business Operations Manager. In the meantime, the Business Operations Manager has started to develop checks and balances. Corrective Action Plan Timeline: Immediately Designation Of Employee Position Responsible For Meeting Deadline: Business Operations Manager