Finding Text
Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, ?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 award.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?. Additionally, Uniform Guidance requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: The Organization has been administering the federal award for over a decade and has hired knowledgeable programmatic staff who have created an environment which understands the mission and purpose of the program. These individuals have not adequately documented their policies and procedures to fully establish an appropriate system of internal control over compliance. This includes a lack of required written policies as well as inadequate documentation of routine control functions such as those items noted in 2022-002 below. The lack of written policies includes required policies under Uniform Guidance sections ?200.302 (b)(6), ?200.302 (b)(7), ?200.305 (b), ?200.319 (c)(1), ?200.319 (c)(2) and ?200.320 (d)(3). Cause and Effect: The lack of appropriate controls and documentation to support processes surrounding the use of federal funds may result in undetected or uncorrected misstatements or instances of noncompliance. The lack of adequate documentation resulted in finding 2022-002 below. Additionally, as the policies referenced above are not written, the Organization cannot be in compliance with the requirements. Recommendation: The Organization should consider implementing policies, procedures, and internal controls specific to federal awards. Policies should be implemented for all applicable compliance requirements, ensuring that there is appropriate documentation to support the controls taking place. We recommend the policies noted above be written by the Organization, approved by the Board of Directors, and included in the permanent files of the Organization. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented their corrective actions as of the date the financial statements were available for issuance.