Finding Text
2022-4 Criteria or Specific Requirement - The Uniform Guidance Section 200.303 requires non-Federal entities to establish and maintain effective internal control over the Federal awards 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 award. Management is responsible for establishing and maintaining processes and internal control over financial reporting. Processes and internal control should allow management or employees, in the normal course of performing their assigned functions to prevent or detect misstatements. Condition and Context - The Organization's processes and internal controls over ACH disbursements during the reporting period did not provide appropriate segregation of duties. ACH disbursements were initiated, executed and recorded in the general ledger by a single individual. Effect - The lack of sufficient segregation of duties puts the Organization at risk for misstatement due to error or fraud. Cause - Lack of experienced and knowledgeable staff to implement sufficient internal control. Recommendation - The Organization should consider hiring more experienced and knowledgeable accounting staff. We believe that due to the size and complexity of the Organization, more experienced and knowledgeable staff is warranted. Views of Responsible Officials and Planned Corrective Action - Management agrees with the finding. The Organization has hired a new Director of Finance and has implemented an ACH approval process with segregated duties as follows: ? External Bookkeeper initiates (and is not able to approve or process). ? Executive Director reviews, approves and processes. ? Director of Finance records.