FARMWORKER JUSTICENon-Profit

Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency) Federal Program: 93.129 - U.S. Department of Health and Human Services Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the Organization is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in excess of allowable costs for the year ended December 31, 2023. As a result, management provided a revised SEFA after the major program determination had already been completed. Because the Organization had not billed the government for the excess expenditures, there were no questioned costs. Cause: The initial SEFA provided by management at the start of the audit was based on the profit and loss statements, which are used to track both federal and non-federal expenditures. However, the profit and loss statements did not specifically identify the non-federal expenditures which were not allowed to be charged to the federal award. Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not accurately prepared, it could have an effect on the auditor's determination of major programs. Recommendation: The Organization should implement procedures to ensure the accurate preparation of the SEFA prior to the start of the audit.

Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency) Federal Program: 93.129 - U.S. Department of Health and Human Services Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: For all disbursements tested, the Organization could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed for all 2023 transactions. However, SAM checks were performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: The Organization was not in compliance with the procurement documentation requirements of the Uniform Guidance. As a result, the Organization could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: The Organization should establish internal controls to ensure proper documentation is maintained as evidence to support that the Organization performed the required suspension and debarment searches on the SAM website. Repeat Finding: Yes. See Finding 2022-002.

Finding 2022-002: Procurement, Suspension, and Debarment (Significant Deficiency) Federal Program: 93.224 - U.S. Department of Health and Human Services Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: For all disbursements tested, the Organization could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Questioned Costs: $- Cause: The Organization did not require evidence of SAM checks be maintained in its vendor files. As a result, the Organization did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed. Despite the lack of documentation, a search was performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: The Organization was not in compliance with the procurement documentation requirements of the Uniform Guidance. As a result, the Organization could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. As a result, the potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: The Organization should establish internal controls to ensure proper documentation is maintained as evidence to support that the Organization performed the required suspension and debarment searches on the SAM website.

Finding 2022-003: Cash Management and Reporting (Significant Deficiency) Federal Programs: 93.224 - U.S. Department of Health and Human Services Criteria or Specific Requirement: 2 CFR Section 200.303 requires auditees to establish and maintain effective internal control over federal awards 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not maintain documentary evidence of the review and approval of either its requests for cash draw downs or its performance reports in accordance with the internal control requirements. Questioned Costs: $- Cause: The Organization's management team works collaboratively to prepare the requests for cash draw downs and prepare the performance reports prior to submission. Per discussion with management, the review and approval is performed verbally during this process. As a result, the Organization was not able to provide adequate support to document the review and approval of either its requests for cash draw downs or its performance reports. Effect or Potential Effect: The Organization was not able to provide evidence of the implementation of internal controls related to review and approval for cash draw downs and performance reports. Therefore, these submissions may have been inaccurately prepared. Recommendation: The Organization should retain documentary evidence of its review and approval process, which should occur prior to submission of the requests for cash draw downs and performance reports.