Core Issue: The Organization lacks written policies required by Uniform Guidance for key areas such as Internal Controls and Travel.
Impacted Requirements: Non-compliance with 2CFR regulations could lead to improper expense management and financial reporting.
Recommended Follow-Up: Update the fiscal manual to include compliant policies and ensure they are adopted by the agency.
Finding Text
#2021-007 – Significant Deficiency – Special Tests
Criteria
Uniform Guidance (UG) requires non-Federal entities that receive grant funding to have written policies in the following areas:
Internal Controls (2CFR 200.303)
Travel (2CFR 200.474)
Financial Management and Accounting which includes Cash Management and Allowability (2CFR 200.302)
Personnel Compensation – Time and Effort Reporting (2CFR 200.430(i))
Conflict of Interest/Disclosures (2CFR 200.318)
Procurement (2CFR 200.319)
Condition
During the audit we noted that the Organization does not have written policies in place over these areas in accordance with Uniform Guidance.
Cause
The Organization was not aware of the requirement to have these written policies in place.
Effect
The potential effect of not having these policies in place is that Organization’s expenses are not in accordance with UGG.
Questioned Costs
None
Perspective Information
No policies or procedures were noted that are in accordance with Uniform Guidance. As a response to the prior year finding, the Organization noted that they will add policies to the fiscal manual for future compliance.
Identification as a repeat finding
A similar issue was noted in prior year finding #2020-007.
Recommendation
We recommend that the Organization update the fiscal manual to include policies that are compliant with Uniform Guidance.
View of responsible officials and planned corrective action
Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.
Corrective Action Plan
Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.