Finding Text
Criteria: Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub. L. No. 116-36m Division A, Title V (2020) requires that the Coronavirus Relief Fund (CRF) monies must be used to cover costs that are:
1. Necessary expenditures incurred due to the public health emergency with respect to COVID-19;
2. Not accounted for in the governments' most recently approved budget as of March 27, 2020; and
3. Incurred during the period that begins on March 1, 2020 and ends on December 31, 2021.
Additionally, 2 CFR 200.303 requires the recipient of federal funds 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 awards.
Condition/Context: We selected a statistically valid random sample of transactions charged to the program of 40 emergency assistance transactions and 12 general disbursement transactions to test controls of disbursement costs charged to the major program and found the following:
- One general disbursement transaction was not supported with appropriate documentation.
- Emergency Assistance transactions were for checks written in 2020 but inappropriately recorded in 2021.
Cause: The primary factor that contributed to the deficiencies was the lack of sufficient controls implemented to appropriately review and monitor disbursement activity and ensure amounts were properly recorded in the general ledger.
Effect: Disbursement transactions were being processed incorrectly. We were unable to obtain sufficient assurance over compliance, and the major program received a qualified opinion.
Questioned Costs: Known and likely questioned costs did not exceed $25,000.
Repeat finding: This finding is a repeat of finding 2020-005 from the prior year.
Recommendation: In order to ensure disbursement transactions are properly reviewed, approved, and supporting documentation is maintained, we recommend the Tribes ensure controls over disbursement procedures are designed and operating effectively.
Views of responsible officials and planned corrective action: The Tribes commit to a comprehensive corrective action plan, including a thorough review of document processes, implementing additional controls for disbursements transactions, ensuring proper documentation review in the future, enhancing controls over the timing of expenditure recognition, and providing additional training, to personnel involved in disbursement process.