Finding Text
Finding: 2023-001 Document Retention
Awarding Agency and Pass through Entity: U.S. Department of the Treasury, passed through Lane
County (Contract 512211-285-3427062)
Federal Award: Emergency Rent Assistance Program (ALN 21.023)
Compliance Requirement: Eligibility
Finding Type: Significant Deficiency in Internal Control Over Compliance.
Criteria: 2 CFR 200.334 Retention requirements for records requires that documentation pertinent to
the federal award be retained for a period of three years from the end of the program. Internal controls
should be appropriately designed and implemented to ensure compliance with all applicable rules and
regulations.
Condition: 1 of 25 participant files could not be located. Checklists completed during file review to
ensure participant files are complete and accurate were not retained after the review was performed.
The program had 144 participants during fiscal year 2023. No questioned costs or potentially improper
payments were noted.
Cause: Employees did not follow the organization's document retention policy and certain records were
not identified as needing to be retained.
Effect: Not retaining documents as required could lead to questioned costs and the inability to
demonstrate compliance with all applicable award terms and conditions, as well as not being able to
demonstrate the operating effectiveness of internal controls over compliance.
Recommendation: Internal controls and processes should be implemented to ensure all pertinent
documentation is retained and the organization's record retention policy is followed by all employees.
Management response: Management concurs with the finding. Corrective actions will be taken to
ensure documentation is retained appropriately.