Finding 58687 (2022-002)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-04-20
Audit: 53879
Organization: Disability Rights Washington (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over compliance, leading to noncompliance with allowable cost principles for federal awards.
  • Impacted Requirements: U.S. CFR 200 requires that expenditures for federal awards be accurately documented and allowable, which was not met in three instances due to coding errors.
  • Recommended Follow-up: DRW should enhance internal controls to ensure all costs charged to federal awards comply with regulations and internal policies.

Finding Text

Finding 2022-002 Significant deficiency in internal controls over compliance and instances of noncompliance related to allowable costs/cost principle compliance requirements. Federal Agency: U.S. Department of Education Program Title: Program of Protection and Advocacy of Individuals Rights Assistance Listing Number: 84.240A Awards Number: H240A220048-22A & 22B Award Period: 10/01/2021 - 9/30/2022 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E require expenditures allocated to federal awards be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable, properly allocated, and supported by adequate documentation. Condition/Context For the year ended September 30, 2022, in a sample of 40 transactions, there were three instances of costs being charged to the award that were not consistent with DRW?s policies and procedures, or consistent with other federal and non-federal awards. The three charges were erroneously charged to the award due to a coding error. This was not a statistical sample. Effect/Potential Effect DRW did not fully comply with the allowable cost principles as specified in Federal Regulations. As a result, there may be charges to the award that are not allowable. Questioned Costs Award H240A220048-22A & 22B: $318.70 Cause DRW?s internal controls related to allowable cost allocation was not sufficient to prevent or detect errors in compliance with the standards and to ensure consistent treatment with policies and procedures. Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure that all costs charged to the federal awards are allowable under Federal Regulations and follows DRW?s policies and procedures for consistent treatment. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.

Corrective Action Plan

Response to finding 2022-02 ? Significant Deficiency in Internal Controls Over Compliance and Instances of Noncompliance Related to Unallowable Costs Contact Person(s): Mark Stroh (mstroh@dr-wa.org) and Justin Gifford (justing@dr-wa.org). Corrective action planned: o DRW will modify its internal controls to ensure that all costs charged to the federal awards are allowable under Federal Regulations and follow DRW?s policies and procedures for consistent treatment. Steps: 1. Consolidate what constitutes an unallowable expenditure under federal regulations in a one pager for use in training fiscal staff, program staff, development staff and staff who submit expense reimbursements. Include expenditures that are in a gray area and subject to interpretation, so they are charged to an unrestricted fund. 2. Revise instructions and provide training for coding and approving fund allocations in Concur to emphasize accuracy of coding before it reaches Controller. 3. Revise instructions and provide training for Controller to emphasize the catching of mistakes made during Concur entry and approval before they are entered into Abila. 4. Revise instruction and provide training for reviewing cost center expenditure reports by program directors to emphasize how to understand the information and how to catch coding errors made during the Concur/ Abila entry and approval processes, particularly those which involve using federal dollars for unallowable expenditures. 5. Have Fiscal Monitor routinely verify that all involved employees have received the training described above and are performing their duties consistent with that training. Attention should be paid to ensure that regular reports are made to the Executive Director and involved employees with the results from this monitoring. 6. Go back to charging all technology related expenses (such as computers, computer repairs and accessories) to Cost Center 23 which is allocated on an equitable basis across all funds. Anticipated completion date: April 30, 2023.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 635129 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.138 Protection and Advocacy for Individuals with Mental Illness $562,904
84.240 Program of Protection and Advocacy of Individual Rights $348,219
93.843 Acl Assistive Technology State Grants for Protection and Advocacy $90,479
93.630 Developmental Disabilities Basic Support and Advocacy Grants $80,574
93.873 State Grants for Protection and Advocacy Services $76,427
96.009 Social Security State Grants for Work Incentives Assistance to Disabled Beneficiaries $73,636
93.618 Voting Access for Individuals with Disabilities-Grants for Protection and Advocacy Systems $49,782
21.027 Coronavirus State and Local Fiscal Recovery Funds $14,038