Christina Cultural Arts Center, Inc.

Federal agency: U.S. Department of the Treasury Federal program title: Coronavirus Capital Projects Fund Assistance Listing (ALN): 21.029 Pass-through agency: State of Delaware Period of performance: Through December 31, 2026 Finding Number: 2024-001 Type of finding: - Significant Deficiency in Internal Control over Compliance, and - Noncompliance with 2 CFR §200.510(b) (SEFA completeness) Criteria or Specific Requirement: - SEFA content and completeness. Under 2 CFR §200.510(b), the auditee must prepare a complete Schedule of Expenditures of Federal Awards (SEFA) listing each federal program by federal agency and ALN, and for subawards, the pass-through entity’s name and identifying number. - Auditor reporting. Audit findings must be reported under 2 CFR §200.516(a) when there is material noncompliance and/or significant deficiencies/material weaknesses related to federal programs. Condition: During the audit, we noted that the Organization’s initial SEFA did not include all federal pass-through awards, including certain U.S. Department of the Treasury – Coronavirus Capital Projects Fund (ALN 21.029) subawards administered by the state of Delaware. The additional federal awards were identified by the auditors and subsequently added to the SEFA prior to report issuance. Questioned Costs: None were identified as part of this finding. Context: The omission was identified during SEFA procedures and major program determination. Because the SEFA is the basis for planning and selecting major programs, initial incompleteness could have affected major program determination and compliance testing. (SEFA must include ALN, pass-through, and award IDs per 2 CFR §200.510(b); audit findings are required to be reported per §200.516(a).) Cause: Controls over SEFA preparation and federal award identification were not sufficient to ensure all pass-through federal awards (including ARPA CPF) were captured with required identifiers (federal agency, ALN 21.029, pass-through name/number) before year-end reporting. Effect: An initially incomplete SEFA increases the risk that: - major programs are not properly identified for testing (§200.518) - the auditor may need to modify the SEFA in-relation-to opinion or compliance opinion if not corrected before report issuance (§200.515). - cause a delay in the audit Repeat Finding: No Recommendation: We recommend management implement (and document) SEFA preparation controls to ensure completeness and accuracy, including: 1. Maintaining a central grant repository containing award documents with federal agency, ALN (21.029), FAIN/prime award, pass-through entity, pass-through ID(s), period of performance, and award amounts. 2. Performing a year-end SEFA reconciliation from the general ledger and grant subledger to the repository, confirming all pass-through awards are captured with required ALN and identifiers per §200.510(b). 3. Obtaining written ALN/FAIN confirmations from pass-through entities for any awards lacking federal identifiers and retaining those confirmations in the grant file. Views of Responsible Officials: Christina Cultural Center experienced a SEFA completeness finding during a year with bookkeeping turnover, which affected the initial compilation of federal award activity. In response, management worked closely with the audit team to confirm the complete listing of awards, validate pass-through entity details, and support accurate SEFA presentation. The organization has also identified cross-training as a key next step to strengthen continuity and reduce key-person dependency going forward.