Boys & Girls Clubs of Indianapolis, Inc.Non-Profit

2024-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Significant Deficiency in Internal Control Over Compliance and Noncompliance – Inadequate Documentation Non-payroll Transactions B. Allowable Costs/Cost Principles Criteria: Per 2 CFR § 200.403(g), charges to federal awards should be adequately documented to determine allowability of costs. Condition and Context: We haphazardly selected a sample of 25 non-payroll transactions. Our sample was not statistically valid. During our testing of non-payroll expenses charged to the federal program, we noted two instances for the 25 transactions selected for testing where the documentation retained was not adequate to support allowable cost determinations. These two transactions resulted in questioned costs that totaled $732. Cause and Effect: Control activities for retaining supporting documentation did not operate consistently as designed throughout the year. As a result, certain costs were recorded to federal awards without adequate supporting documentation, resulting in questioned costs and increasing the risk of unauthorized or otherwise unallowable expenditures. Recommendation: We recommend that management train staff on documentation retention policies. Management should also implement preventative or detective controls to ensure adequate documentation is retained for federal awards. Views of Responsible Officials and Planned Corrective Action: Management agrees with the recommendation and it was implemented effective July 1, 2025.

U.S. Department of Education and Corporation for National and Community Service 2019-003 Twenty-First Century Community Learning Centers ? CFDA #84.287 and AmeriCorps ? CFDA #94.006 Significant Deficiency in Internal Control Over Compliance and Noncompliance ? Allowable Costs/Cost Principles and Cash Management Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: BGCI does not have the written policies in place in accordance with ?200.302 Financial Management paragraph (b)(6) and (b)(7). This is a repeat finding of 2018-003 and 2017-003. Cause and Effect: As the policies referenced above are not written, BGCI cannot be in compliance with the requirements. In addition, lack of written policies related to financial management may lead to noncompliance with allowable costs/cost principles and cash management requirements. Recommendation: We recommend the policies in accordance with ?200.302 Financial Management paragraph (b)(6) and (b)(7) be written by BGCI, approved by the Board of Directors and included in the permanent files of BGCI. Views of Responsible Officials and Planned Corrective Actions: BGCI agrees with the recommendation that the policies in accordance with 200.302 Financial Management paragraph (b)(6) and (b)(7) be written by BGCI, approved by the Board of Directors and included in the permanent files of BGCI. These policies were written and approved by the Board in November 2020, and are maintained in the permanent files of BGCI.

2019-004 Twenty-First Century Community Learning Centers ? CFDA #84.287 Significant Deficiency in Internal Control Over Compliance and Noncompliance ? Allowable Costs/Cost Principles Criteria: In accordance with 2 CFR 200.403(g), all costs must be ?adequately documented? to be considered allowable. In accordance with ?200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal awards to provide reasonable assurance of managing the Federal award in compliance with Federal statues, regulations, and terms and conditions of the Federal award. Condition and Context: We selected 60 general disbursements for testing. Our sample was not a statistically valid sample. Of the items selected the following issues were noted: (a) 2 of 60 items did not have approval on the purchase order or financial form by the appropriate member of management as prescribed by internal policies. (b) 4 of the 60 items, all relating to the same vendor, had no available documentation. This resulted in known questioned costs of $118 based on the amount of undocumented expenditures recorded. (c) 5 of 60 items did not have a purchase order or financial form. This resulted in known questioned costs of $307 based on the amount of undocumented expenditures recorded. This is a repeat finding of 2018-004 and 2017-004. Cause and Effect: If costs are not adequately documented, allowability cannot be determined. Consequently, the costs relating to the receipts are unallowable. The presence of unallowable costs can result in funding being suspended or revoked or repayment of any reimbursements associated with unallowable costs. The lack of appropriate management approval could result in costs being improperly charged to the program. Recommendation: We recommend appropriate documentation, including purchase orders or financial forms with proper approval, receipts, and any other necessary information be retained for each disbursement. Views of Responsible Officials and Planned Corrective Actions: BGCI agrees with the recommendation that appropriate documentation, including purchase orders or financial forms with proper approval, receipts and any other necessary information be retained for each disbursement. BGCI made a conscious effort was made to enforce the policy that all expenses charged to a grant be reviewed and approved by a Director at the Senior Leadership level, which is reflected in the sharp decrease in the number of exceptions.

2019-005 AmeriCorps ? CFDA #94.006 Significant Deficiency in Internal Control Over Compliance and Noncompliance ? Allowable Costs/Cost Principles Criteria: In accordance with 2 CFR 200.403(g), all costs must be ?adequately documented? to be considered allowable. In accordance with ?200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal awards to provide reasonable assurance of managing the Federal award in compliance with Federal statues, regulations, and terms and conditions of the Federal award. Condition and Context: We selected 60 time cards for testing from 8 payroll periods. Our sample was not statistically valid samples. Of the items selected the following issues were noted: (a) 19 of 60 time cards we selected were approved after the pay date. Approval of timecards did occur but not as prescribed by internal policies, specifically as a preventative control. (b) 2 of the 8 payroll periods contained costs charged to the program not supported by the related payroll reports. This resulted in known questioned costs of $1,400 based on the amount of undocumented expenditures recorded. Cause and Effect: If costs are not adequately documented, allowability cannot be determined. Consequently, the costs relating to the receipts are unallowable. The presence of unallowable costs can result in funding being suspended or revoked or repayment of any reimbursements associated with unallowable costs. The delayed approval of these time cards could result in costs being improperly charged to the program. Recommendation: We recommend timely review of time cards occurs so grant coding can be reviewed before costs are incurred. Additionally, we recommend the expenses be reviewed in detail for the grant code in which they are charged prior to submission for reimbursement so any adjustments between grants can be completed and to ensure that the cost is charged to the proper grant. Views of Responsible Officials and Planned Corrective Actions: BGCI agrees with the recommendation that all timecards should contain supervisory approval for time worked. All timecards do contain an electronic supervisor approval. BGCI changed their process to print the timecards with the electronic approval of the supervisor showing. BGCI?s handbook was updated in 2020 to include additional compliance language related to timecards. BGCI also agrees expenses should be reviewed in detail for the grand code in which they are charged prior to submission for reimbursement. BGCI will make a conscious effort to enforce the policy that all expenses charged to a grant be reviewed and approved by a Director at the Senior Leadership level

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION