Finding Text
Information on the Federal Program: Assistance Listing Number 21.027?American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of the Treasury. Pass-Through Entities and Award Numbers: Minnesota Department of Agriculture, award number 207317 Minnesota Department of Human Services, award number 208490. Compliance Requirement: Allowable Costs. Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Activities Allowed or Unallowed, Allowable Costs and Cost Principles. Condition: Processes and procedures in place to track spending on the grant did not include a specifically documented review or approval of item numbers or purchase orders. Cause: One individual places purchase orders and enters purchase information in a tracking spreadsheet. Invoices are prepared from the tracking spreadsheet. Item numbers are created to track allowable items but no review is required. A manager has overall oversight but no specific review is documented. Effect or Potential Effect: Unallowable costs or activities could be charged to the grant. Questioned Costs: None Context: No documented review or approval control was identified. Repeat Finding: No Recommendation: We recommend the sourcing director begin reviewing purchase orders and item numbers used in the program and document such review on at least a monthly basis. Views of Responsible Officials: Agree and controls have now been implemented.