Women of NationsNon-Profit

2023-002 Federal agency: U.S. Department of Justice Federal program title: Crime Victim Assistance Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Office of Justice Programs Type of Finding: - Material Weakness in Internal Control Over Compliance - Other Matters Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 specifies that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation of time and effort was not maintained for 1 out of 20 employees tested under the program to support the amounts charged to grants. In addition, none of the timesheets selected for testing had formal documentation of review or approval. Questioned Costs: $11,538 Context: We tested 66 timesheets for 20 different individuals who charged time to the grant during the period tested. Time and effort documentation was not maintained for 4 out of 66 timesheets selected for testing under the program, which related to one individual. None of the timesheets selected for testing had formal documentation of review or approval. Cause: Proper internal control processes and procedures were not in place to document personnel time charged to the grant. Effect: Program could be over or under billed if time and effort is not calculated correctly from employee certifications or supported by approved timesheets. Recommendation: We recommend that WON implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. We recommend that all additional amounts paid contain documentation that they are properly authorized. We recommend that all employees have timesheets to support the hours worked and charged to the grant. These timesheets should be formally approved by a supervisor. Views of responsible officials: WON will ensure that all timesheets are completed and properly approved going forward to ensure that time and effort is documented.

Material Weakness in Internal Control Over Compliance Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 specifies that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation of time and effort was not maintained for any employee under the program. In addition, documentation of approved pay rates and documentation of timesheets to support the amounts charged to grants was not retained. Context: Time and effort documentation was not maintained for any employee under the program. Noted that pay rates are based on new employee information forms or payroll change notice form that are approved by the Director of Finance or a supervisor. Noted that 2 of the 8 individuals selected for testing did not have documentation of approval on the forms. Noted 1 of the 8 individuals selected for testing did not have documentation of the amount of the pay rate change on the payroll change notice form that is approved by the Director of Finance or a supervisor. Noted that one person received $50 hazard pay amount per payroll period after the beginning of COVID. WON did not have documentation of review and approval of this. Noted that 4 of the 8 individuals selected for testing had missing timesheets to support the amounts charged to the grant. Questioned Costs: $14,522 Cause: Proper internal control processes and procedures were not in place to document personnel time charged to the grant, pay rate changes, and hazard pay amounts. Effect: Program could be over or under billed if time and effort is not calculated correctly from employee certifications or supported by approved timesheets or pay rates. Recommendation: We recommend that WON implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. We recommend that all pay rate changes contain documentation of approval. We recommend that all pay rate change forms contain documentation of the pay rate change amount and the new hourly or salary rate as a result of that change. We recommend that all additional amounts paid contain documentation that they are properly authorized. We recommend that all hourly employees have timesheets to support the hours worked and charged to the grant. Views of responsible officials: WON will begin use of a new payroll application that will allow for time tracking across different payers. WON will review the allocation of costs across granters every 6 months to ensure their continued accuracy as individuals? roles change over time.

Material Weakness in Internal Control Over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.303 specifies that a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Documentation of review and approval of general disbursements was not adequate. Context: WON is currently approving a vendor summary report that lists the invoices to approve rather than the invoices itself. 15 of 17 of the disbursements selected for testing were paid via credit card. The amount paid each period to the credit card provider and the amount on the vendor summary report that contained the documentation of approval were not the same amounts and thus were not adequately approved. Questioned Costs: $1,701 Cause: Lack of sufficient documentation of approval of general disbursements Effect: Unallowable or improper costs could be charged to the program. Recommendation: We recommend that WON document approval on each invoice rather than on the vendor summary report to ensure that all amounts are properly approved. In addition, we recommend that WON follow its policies regarding approval of credit card statements by the board chair. Views of responsible officials: WON as already implemented signed approval by the CEO and Finance Director on each individual invoice.

Material Weakness in Internal Control Over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.303 specifies that a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Documentation of review and approval of cash management reports was not adequate. Context: Of the 11 FSRs selected for testing, we noted that 4 did not have documentation of approval prior to submission. Cause: Proper internal control processes and procedures were not in place to provide evidence of review and approval of FSRs. Effect: Amounts requested for reimbursement could contain errors or improper amounts without a review process in place Recommendation: We recommend that WON retain documentation of approval for each FSR that is submitted during the year. Views of responsible officials: WON will ensure approval is given in writing, even when approval is initially given verbally.

? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.303 specifies that a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. WON is required under the terms of the award to submit a quarterly statistical report, annual statistical report, quarterly program income report and annual financial report. Condition: Documentation of review and approval of reports was not adequate. Documentation to support the information used in the statistical reports was not retained and the changes within the system caused the information to not agree to the numbers used at that time. Context: Of the 3 statistical reports selected for testing, we noted that the information from the Apricot System, system used to maintain statistical information, did not agree to the information used for the statistical reports. It was noted by management that changes could be made to the Apricot System after the report was originally generated causing those differences. We also noted that for the 6 total reports selected, including both the statistical reports and quarterly program income reports, we did not see evidence of documentation of review. Cause: Lack of documentation of review of reports and lack of document retention related to statistics used. Effect: Incomplete or inaccurate information could be provided to grantor. Recommendation: We recommend that WON have a process in place to review all reports submitted and documentation of review is retained. We recommend that information regarding statistics are retained so that the amounts used could be reperformed. Views of responsible officials: Complete records will be kept of source documentation for all reports. All reports will have written documentation of review via email.

? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.306 (b) requires that any matching funds must meet certain criteria, including that they are verifiable from the records of the organizations, are necessary and reasonable for accomplishment of program objectives, are allowable under cost principles of Uniform Guidance, and conform to other provisions. Cost principles at ?200.430 specify that charges for salaries and wages must be based on records that accurately reflect the work performed. Additionally, ?200.306 (e) requires that rates used for third-party volunteer services must be consistent with those paid for similar work. Condition: Documentation of approved rates for university and elder volunteer time was not retained. Tracking sheets used to substantiate university volunteer hours and elder hours was not retained. Context: 2 of the 12 selections for matching related to the use of volunteer hours for university volunteers and elder volunteer time. WON did not have support that the rate used for the volunteer hours for either the university or elder volunteers was approved. Noted that 1 of the 2 selections for volunteer hours was missing tracking sheets to substantiate the hours for the university and elder volunteers. Cause: Support for rates used and volunteer tracking sheet was not maintained. Effect: Amounts claimed for required matching could be inaccurate. Recommendation: We recommend that WON retain documentation supporting the rate used for university and elder time charged to the grant, ensuring that it meets the requirements of ?200.306 (e). In addition, we recommend that WON retain tracking support for all volunteer hours used, and put review procedures in place to ensure time reported is accurate. Views of responsible officials: WON currently has all volunteers complete timesheets, WON staff reconciles these time sheets with the volunteers? reported hours to their Universities. WON will continue this process and will keep all documentation of timesheets. WON will reach out to OJP to confirm the proper rates are being used for all volunteer match.