NATIONAL RESOURCE CENTER ON DOMESTIC VIOLENCE, INCNon-Profit

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Reporting Criteria: The Organization is required to submit annual and semi-annual Federal Financial Reports (FFR) in accordance with the cooperative agreement between the Organization and the U.S. Department of Health and Human Services. Condition: Four of the five report samples selected for testing were filed late in accordance with the guidelines set forth in the cooperative agreement. The delinquent reports sampled were uploaded to the portal within the applicable guidelines; however, due to staffing turnover, they were unable to be certified by an appropriate personnel within the organization. Cause: Staffing turnover did not allow for appropriate adherence to reporting requirements. Effect: The absence of timely submission of reports inhibits the Organization from complying with federal program requirements and the potential of loss of funding from federal agency. Recommendation: The Organization should establish procedures and controls to ensure financial and performance reports are filed in a timely manner.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.403(g) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), all costs must be adequately documented. This includes all invoices or other supporting documentation associated with program expenses should be retained to ensure the expense was in accordance with the requirements of the federal program and reported appropriately. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization?s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide approximately 17% of the invoices or other supporting documentation selected for testing that are associated with certain program expenses incurred. Cause: The Organization is understaffed and has experienced significant turnover in the accounting and finance department which makes it difficult to maintain internal controls designed to reasonably assure compliance with federal laws, regulations, and program compliance requirements. Effect: The absence of expenditure supporting documentation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures. View of Responsible Officials: A former Board member with finance and operations experience has been tasked with reviewing financial policies and procedures to ensure compliance in all areas. Policies and procedures will be updated with new processes. To date there have been two changes implemented. Finance staff must now attach electronic copies of invoices within the accounting system to corresponding transactions in order to process payment. In addition, a report of credit card charges missing required documentation is circulated to management monthly, with follow-up to the individual purchasers. Training for all members of the department will occur on an ongoing and regular basis to ensure best practices are being upheld. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.403(g) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), all costs must be adequately documented. This includes all invoices or other supporting documentation associated with program expenses should be retained to ensure the expense was in accordance with the requirements of the federal program and reported appropriately. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide approximately 17% of the invoices or other supporting documentation selected for testing that are associated with certain program expenses incurred. Cause: The Organization is understaffed and has experienced significant turnover in the accounting and finance department which makes it difficult to maintain internal controls designed to reasonably assure compliance with federal laws, regulations, and program compliance requirements. Effect: The absence of expenditure supporting documentation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization?s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures. View of Responsible Officials: As part of the ongoing review of procedures, all wage changes must now be approved in writing by the CEO or her designee for all subordinate staff, and by the Board of Directors for the CEO. All wage changes will be submitted to the payroll processor before any adjustments can be made in the system. Additionally, each payroll is reviewed by a second person to ensure compliance. All supporting documentation of compensation changes will also be placed in the employee's personnel file. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.403(g) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), all costs must be adequately documented. This includes all invoices or other supporting documentation associated with program expenses should be retained to ensure the expense was in accordance with the requirements of the federal program and reported appropriately. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization?s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide approximately 17% of the invoices or other supporting documentation selected for testing that are associated with certain program expenses incurred. Cause: The Organization is understaffed and has experienced significant turnover in the accounting and finance department which makes it difficult to maintain internal controls designed to reasonably assure compliance with federal laws, regulations, and program compliance requirements. Effect: The absence of expenditure supporting documentation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures. View of Responsible Officials: A former Board member with finance and operations experience has been tasked with reviewing financial policies and procedures to ensure compliance in all areas. Policies and procedures will be updated with new processes. To date there have been two changes implemented. Finance staff must now attach electronic copies of invoices within the accounting system to corresponding transactions in order to process payment. In addition, a report of credit card charges missing required documentation is circulated to management monthly, with follow-up to the individual purchasers. Training for all members of the department will occur on an ongoing and regular basis to ensure best practices are being upheld. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.403(g) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), all costs must be adequately documented. This includes all invoices or other supporting documentation associated with program expenses should be retained to ensure the expense was in accordance with the requirements of the federal program and reported appropriately. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide approximately 17% of the invoices or other supporting documentation selected for testing that are associated with certain program expenses incurred. Cause: The Organization is understaffed and has experienced significant turnover in the accounting and finance department which makes it difficult to maintain internal controls designed to reasonably assure compliance with federal laws, regulations, and program compliance requirements. Effect: The absence of expenditure supporting documentation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization?s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures. View of Responsible Officials: As part of the ongoing review of procedures, all wage changes must now be approved in writing by the CEO or her designee for all subordinate staff, and by the Board of Directors for the CEO. All wage changes will be submitted to the payroll processor before any adjustments can be made in the system. Additionally, each payroll is reviewed by a second person to ensure compliance. All supporting documentation of compensation changes will also be placed in the employee's personnel file. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.

Federal Agency: All Program: All Assistance Listing Number: All Major Program Compliance Requirement: All Condition: The required reporting package for the year ended September 31, 2021, was not submitted to the Federal Audit Clearinghouse (FAC) in a timely manner. Criteria: Uniform Guidance requires the reporting package including the audit and data collection form must be submitted to the FAC within the earlier of nine months after the audit period or thirty calendar days after receipt of the auditor?s report. Cause: Staffing resources did not allow for adequate time to properly prepare for the audit causing delays in the process. Effect: Submission of reporting package after required deadline. Questioned Costs: None noted. Recommendation: The Organization should ensure appropriate staff have adequate time to prepare for the audit and work with the audit firm to make sure the reporting package is submitted by the due dates on a go forward basis. View of Responsible Officials: Management was able to hire a Fiscal Manager and Fiscal Specialist to fill open roles (that were open most of 2021) in the finance department as of the report date and has continued to seek assistance from expert external consultants to assist with staffing changes and improve fiscal procedures and policies. NRCDV was impacted by the pandemic and overall shortage of staff regionally which resulted in a key fiscal manager position being vacant for a total of 12 months despite efforts to fill the position. These circumstances resulted in a lack of preparedness for the audit.

Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed, Reporting Condition: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization?s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide approximately 15% of the invoices or other supporting documentation selected for testing that are associated with certain program expenses incurred. Additional costs without supporting documentation related to federal programs was also identified during the financial statement audit. This also led to reports filed with the U.S. Department of Health and Human Services to be potentially inaccurate. Criteria: In accordance with 200.403(g) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), all costs must be adequately documented. This includes all invoices or other supporting documentation associated with program expenses should be retained to ensure the expense was in accordance with the requirements of the federal program and reported appropriately. The agreement with the U.S. Department of Health and Human Services includes requires filing of expenditures on a semi-annual and annual basis. Cause: The Organization is understaffed and has experienced significant turnover in the accounting and finance department which makes it difficult to maintain internal controls designed to reasonably assure compliance with federal laws, regulations, and program compliance requirements. Effect: The absence of expenditure supporting documentation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Questioned Costs: $137,104 Context: There are questioned costs of $137,104 reported in the unadjusted trial balance prepared by the client and coded to federal expenditures. Of the $137,104 in questioned costs: ? $25,000 of expenditures was for a consultant that did not perform services for the Organization in fiscal year 2021. ? $105,996 of expenditures for staff to complete leadership and professional development. Staff were not required to submit documentation to verify the validity of the expenditure. ? $6,138 in expenditures that did not have supporting documentation to verify validity of expenditure. Recommendation: The Organization should retain all supporting documentation for reported expenditures. View of Responsible Officials: Management is working with external consultants to improve the Organization?s overall accounting policies and procedures and will update its practices to be more reliant on electronic documentation rather than paper filing. Staff shortage was a direct result of the pandemic with a key fiscal position being vacant for most of the year along with an office move that contributed to not being able to maintain the usual fiscal controls. In response to the questioned costs: ? Management is requesting $25,000 to be returned to the program from the consultant whose work was disrupted by the pandemic and therefore services could not be rendered. ? Management has requested from staff their tracking of professional development expenditures and will work with each program to verify the validity of the expense. ? Management has implemented a policy to retain electronic documentation of all invoices within the accounting system within fiscal year 2022. Management also has plans to return $130,996 of the questioned costs to the U.S. Department of Health and Human Services.