Finding Text
Finding 2022-005: Internal Controls over Compliance and Other Matters L. Reporting U.S. DEPARTMENT OF JUSTICE Children Exposed to Violence ? Assistance Listing No. 16.818 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) codified in 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, per 2 CFR 200.303, a non-Federal entity must 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 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). Condition: The U.S. Department of Justice?s (DOJ) EDPR of Youthprise?s Children Exposed to Violence Program (re. 2020-CV-FX-K007) noted compliance issues over Youthprise?s Federal Funding Accountability and Transparency Act Subaward Reporting. A formal letter was issued to Youthprise dated November 8, 2022, detailing the compliance issue noted. During our evaluation of controls over financial and performance reporting, it was discovered that evidence to document reports are reviewed and approved prior to submittal is not maintained by Youthprise. Additionally, 2 of the 7 reports selected for testing did not document the date of report submission. Per COSO, segregation of duties should exist between those preparing and those reviewing and filing required reports. Best practices would include ensuring adequate supporting evidence exists to substantiate controls are being followed. Cause: Internal controls were not in place to ensure Youthprise followed the FFATA reporting requirements outlined in 2 CFR Part 170. Internal controls were not in place to document internal controls over reporting were in place and being followed. Effect: The condition noted above resulted in noncompliance over reporting by Youthprise. Context: DOJ completed a EDPR of Youthprise?s Children Exposed to Violence Program (re. 2020-CV-FX-K007) during 2022 and noted Youthprise did not complete the required FFATA reporting as required. The DOJ outlined specific recommendations in its EPDR letter dated November 22, 2022 to address this condition noted and requested resolution to the condition within 20 calendar days. DOJ completed a follow-up site visit at Youthprise on July 10, 2023 and determined the FFATA reporting compliance issue had been adequately resolved. During our audit, Youthprise had described its internal controls in place over reporting, however the auditor was unable to substantiate statements made due to lack of supporting evidence and due to staff turnover at the organization. Questioned Costs: $0 Identification of Repeat Finding: Not a repeat finding. Recommendation: We recommend that Youthprise review its internal control procedures to ensure FFATA reporting is completed as required by 2 CFR Part 170. Additionally, we recommend Youthprise document its review and approval process over reports and document report submission dates. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and is in the process of developing internal controls to ensure timely and appropriate actions are made on the deficiency noted. Additional details can be found in Youthprise?s Corrective Action Plan.