OPPORTUNITIES INDUSTRALIZATION CENTERS OF AMERICA, INC.Non-Profit

Condition and Context: Samples of 40 non-payroll expenditures totaling $1,390,383 under ALN 17.270 and $631,033 under ALN 17.280 were selected for audit from populations of 1,461 expenditures totaling $4,177,292 under ALN 17.270 and 254 expenditures totaling $730,790 under ALN 17.280. The results of the testing were as follows: • Evidence that the expenditure was approved for payment by a person knowledgeable about program requirements could not be located for 21 of the 40 items selected for testing under ALN 17,270, totaling $813,327, and for 21 of the 40 items selected for testing under ALN 17.280, totaling $337,965. • Documentation to support the expenditure could not be located for 15 of the 40 items selected for testing under ALN 17.270, totaling $630,863, and for nine of the 40 items selected for testing under ALN 17.280, totaling $183,068. For many of the expenditures cited in the above two points, neither evidence of payment approval nor documentation to support the expenditure could be located. In total, 23 of the 40 items selected for testing under ALN 17.270, and 21 of the 40 items selected for testing under ALN 17,280, had neither evidence of payment approval nor documentation to support the expenditure that could be located. Criteria: 2 CFR 200 requires that auditees maintain adequate internal controls over compliance, including approval of program expenditures by person knowledgeable about program requirements and maintenance of adequate documentation to support costs incurred. Effect: The costs incurred may not have been allowed under the federal award program. Cause: The Financial Reporting Department of Opportunities Industrialization Centers of America, Inc. (“OICA”) was undergoing significant transition during the audited period. As a result, certain personnel lacked sufficient knowledge about the requirements of federal award programs, and the records to support the selected expenditures were not retained properly to ensure documentation of costs. Questioned Costs: Known questioned costs were $879,797 under ALN 17.270 and $337,965 under ALN 17.280. Recommendation: OICA’s management should reinforce with personnel responsible for recording program charges the need for expenditures to be approved for payment by a person knowledgeable about program requirements and that this approval be documented and retained. OICA’s management should also remind all employees with responsibilities for federal award programs of the requirements to retain documentation supporting compliance. Management’s Response: OICA concurs with the recommendation. In addition, documentation will be archived in OICA’s central SharePoint repository.

Condition and Context: Samples of 19 payroll periods, with 162 employee charges totaling $96,300 under ALN 17.270, and two payroll periods, with three employee charges totaling $5,324 under ALN 17.280, were selected for audit from populations of 111 payroll periods with expenditures totaling $624,021 under ALN 17.270 and 20 payroll periods with expenditures totaling $60,709 under ALN 17.280. All employees who charged time during these payroll periods were selected for testing. For 19 of the 162 employee charges selected for testing under ALN 17.270 and two of the three employee charges selected for testing under ALN 17.280, the amount of payroll costs charged to the federal award programs exceeded the amount that should have been charged, based on the actual hours worked by the employees on the applicable federal award program. Criteria: 2 CFR 200 requires that auditees support payroll costs with appropriate supporting documentation, including pay rates and direct labor hours worked on federal award programs. Effect: The costs incurred may not have been allowed under the federal award program. Cause: OICA’s Financial Reporting Department was undergoing significant transition during the audited period. As a result, the records to support the selected expenditures were not retained properly to ensure documentation of costs. Questioned Costs: Known questioned costs were $9,203 under ALN 17.270 and $420 under ALN 17.280. Recommendation: OICA’s management should reinforce with personnel responsible for recording program charges the need for expenditures charged to federal award programs to reflect expenditures based on actual hours and pay rate. Management’s Response: OICA concurs with the recommendation.

Condition and Context: We selected for testing four months during which draw downs occurred for the grant program. For three of the four periods selected for testing, the amount drawn down exceeded the expenditures incurred for the same period of time, indicating that funds were not disbursed prior to the request. Criteria: 2 CFR 200 requires that auditees not request payment for cost-reimbursement contracts under federal acquisition regulations until the funds have been disbursed or otherwise been obligated. Effect: OICA was not in compliance with the cash management requirements of the federal award program. Cause: OICA’s Financial Reporting Department was undergoing significant transition during the audited period. As a result, certain personnel lacked sufficient knowledge about the cash management requirements of federal award programs. Questioned Costs: None. Recommendation: OICA’s management should reinforce with personnel responsible for requesting reimbursement the requirement that funds be disbursed or obligated prior to the request. Management’s Response: OICA concurs with the recommendation.