EIN: 770556795
UEI: PAFCR8LS8TF1
Audited by: MCGOWAN GUNTERMANN
Oversight agency: 64 [Department of Veterans Affairs]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (27 days from today).
What is a management decision? →FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
Criteria Part 2, CFR Part 200.430 notes “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed”. The document continues to state that documentation must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Additionally, Part 200.431 states “The cost of fringe benefits in the form of regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave, holidays, court leave, military leave, administrative leave, and other similar benefits, are allowable is all of the following criteria are met:”. The criteria include that “the costs are equitably allocated to all related activities, including Federal awards.” Condition While performing tests of NBCC’s internal controls over payroll transactions, we noted the Organization had incorrectly allocated time for 8 of the 50 selections. Additionally, we noted that the Organization had allocated time for leave based on pre-determined budgets, rather than actual hours worked in the pay period, for 27 of the 50 selections. Cause NBCC has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from Federal awards. Recommendation We recommend NBCC implement proper internal control procedures to document hours worked, by employee and by grant; and maintain the documentation to support charges allocated to each Federal award.
Show full finding ▾Hide full finding ▴Criteria Part 2, CFR Part 200.430 notes “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed”. The document continues to state that documentation must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Additionally, Part 200.431 states “The cost of fringe benefits in the form of regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave, holidays, court leave, military leave, administrative leave, and other similar benefits, are allowable is all of the following criteria are met:”. The criteria include that “the costs are equitably allocated to all related activities, including Federal awards.” Condition While performing tests of NBCC’s internal controls over payroll transactions, we noted the Organization had incorrectly allocated time for 8 of the 50 selections. Additionally, we noted that the Organization had allocated time for leave based on pre-determined budgets, rather than actual hours worked in the pay period, for 27 of the 50 selections. Cause NBCC has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from Federal awards. Recommendation We recommend NBCC implement proper internal control procedures to document hours worked, by employee and by grant; and maintain the documentation to support charges allocated to each Federal award.
iv. Management Response and Corrective Action Plan: Program staff allocate their time spent at work each day based on their client load and recurring weekly activities, e.g., case conferencing meetings. Staff must allocate their daily time and activity hours on their timesheets corresponding to the project/s each client is enrolled in. Leave allocations should reflect each payroll period’s project time and activity actual percentages. Staff must manually record this information on complicated timesheets and consequently errors are made as not all staff are equally administratively adept. While there are multiple levels of review over timesheets, as the company has grown, it has become apparent that NBCC must integrate a more reliable method of always ensuring accurate allocation calculation of regular and leave hours. The expectation was that our new payroll solution provider, Paychex, was going to custom tailor a system that prevented such calculation errors, but this has not been the case thus far. Therefore, NBCC is actively once again researching payroll companies in an effort to find a solution better aligned with our timesheet needs. In the interim, management will work to edit our existing timesheet template to create a more user-friendly timesheet tool that auto-calculates where necessary and as appropriate so as to avoid misallocation. Management will also conduct additional timesheet trainings with staff as necessary. The end goal will be to secure a new payroll solution provider with system functionality that eliminates this kind of human error. v. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administration Director, vgarfield@sbnbcc.org Michael Dzierski, Finance Director, mdzierski@sbnbcc.org vi. Anticipated Completion Date: The anticipated completion date of the first step of editing our existing timesheet and retraining all staff as necessary is June 30, 2025. The anticipated completion date of the second step of having an integrated new payroll system with a new payroll solution provider will be dictated by the identification of a new vendor, and the subsequent development and implementation process of the new system, with an estimated completion date of December 31, 2025.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, the Subrecipient Agreement, with the County of Santa Barbara, notes NBCC “shall obtain written approval from COUNTY for the use of any funds provided under this Agreement for the reimbursement of any costs incurred for travel outside the County of Santa Barbara.” Condition Two of the 25 expenditures selected for testing, associated with the above award, were related to travel outside of the County of Santa Barbara. We subsequently reviewed the detail of expenditures charged to this award, noting multiple other transactions. Additionally, we noted the client did not have prior approval to allocate funds to this award. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow improper expenditures to be charged to Federal awards. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
Show full finding ▾Hide full finding ▴Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, the Subrecipient Agreement, with the County of Santa Barbara, notes NBCC “shall obtain written approval from COUNTY for the use of any funds provided under this Agreement for the reimbursement of any costs incurred for travel outside the County of Santa Barbara.” Condition Two of the 25 expenditures selected for testing, associated with the above award, were related to travel outside of the County of Santa Barbara. We subsequently reviewed the detail of expenditures charged to this award, noting multiple other transactions. Additionally, we noted the client did not have prior approval to allocate funds to this award. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow improper expenditures to be charged to Federal awards. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of CoC and ESG grant funds. We perceived the historical general approval to be in alignment with the contract requirement of obtaining written approval for the reimbursement of costs incurred for travel outside the county. All costs submitted for reimbursement were eligible and reasonable expenses. We now understand this historical approval by HUD was not transferrable to this grant and therefore, moving forward, we will secure email approval of travel eligibility for specific grant reimbursement prior to travel. To that end, we have already been in contact with Housing and Community Development (HCD) fiscal staff at Santa Barbara County about a reliable method to secure said approvals in advance moving forward. If travel is not approved for a specific grant, or not obtained prior to travel, other unrestricted income will be utilized for that portion of the travel expenses. viii. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administrator, vgarfield@sbnbcc.org ix. Anticipated Completion Date: Staff anticipate attending the annual NAEH conference this year, therefore we will request approval once registration is confirmed and expect to receive approval or rejection from County CD staff by no later than the date of travel, or approximately July 15, 2025.
Criteria Part 2, CFR 200, 200.318 states “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.” Condition While performing tests of NBCC’s internal controls over compliance, while the Organization did have a procurement policy, the policy was not being followed. This included not obtaining and documenting competitive bids or quotes, as well as not verifying whether vendors are suspended or debarred entities. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines. Repeat Finding No. Effect Noncompliance may impact future funding from Federal awards. Additionally, lack of compliance may lead to contracting with ineligible vendors. Recommendation We recommend NBCC implement proper internal control procedures including implementing and following a procurement policy in line with the Uniform Guidance.
Show full finding ▾Hide full finding ▴Criteria Part 2, CFR 200, 200.318 states “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.” Condition While performing tests of NBCC’s internal controls over compliance, while the Organization did have a procurement policy, the policy was not being followed. This included not obtaining and documenting competitive bids or quotes, as well as not verifying whether vendors are suspended or debarred entities. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines. Repeat Finding No. Effect Noncompliance may impact future funding from Federal awards. Additionally, lack of compliance may lead to contracting with ineligible vendors. Recommendation We recommend NBCC implement proper internal control procedures including implementing and following a procurement policy in line with the Uniform Guidance.
x. Management Response and Corrective Action Plan: The first of the two identified vendors – Maxim/Amergis - is an employment agency with a specialty in staffing providers who work in the healthcare and social services field. NBCC was seeking to hire an RN. Significant documentable effort was invested in hiring an RN with the necessary experience to fill our vacant RN Healthcare Navigator position. After months of being unable to find an appropriate candidate, NBCC sought consultation from the Santa Barbara County Department of Public Health who advised us of the name of the employment agency (Maxim/Amergis) that is used by the Department of Public Health and Department of Behavioral Wellness to staff their RN positions. We reached out to Maxim/Amergis, provided them with the job listing, and reviewed resumes and interviewed candidates until we found an appropriate match. This was a prolonged and involved process where we spent a significant amount of time working to hire the best suited RN for working in the field with the homeless and formerly homeless individuals we serve. We did not perceive this to be a traditional procurement effort and therefore did not create a written analysis of our efforts to identify and hire an RN, nor did we conduct a SAM search on the company given that the company routinely staffs our departments of behavioral and public health. The second identified vendor is Paychex. We believe our efforts to secure a new payroll solution company were very much aligned with Uniform Guidance rules. Our external accounting firm and multiple staff spent more than one year interviewing multiple potential payroll solution providers, including but not limited to, Paychex, ADP, ClickUp, Inova, Credible, and Replicon, among others. We only reviewed two written cost proposals because only two of the researched and consulted companies were able to provide a solution that could potentially meet our government timesheet needs. We conducted multiple meetings with our external accounting firm and internal staff discussing and analyzing the solution options, but a summary of these discussions was not created. In addition, Paychex is a provider to a number of nonprofits we consulted, including a local grantee who was using their service, and who we were advised had developed a system similar to what we needed for our time and activity reporting requirements. We therefore presumed Paychex was not a debarred contractor given that other nonprofits we spoke to who have the same funding were utilizing their services. Moving forward, we recognize we must write a written analysis of our processes and that we should not assume a vendor has not been debarred given their existing customers and will be sure to confirm a company’s standing on SAM. As a further example of our commitment to always remaining current with procurement standards, at the direction of the Executive Director, our Operations Director had previously enrolled in a two-day Procurement Boot Camp training which occurred this week. Our Operations Director will revisit our procurement process as a result of this finding and after attending the procurement training and will make revisions to our procurement process as necessary to ensure future compliance with Uniform Guidance. Any updates will be made to the NBCC Internal Controls Manual and any new processes will be adhered to subsequent to those revisions. xi. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Brenda Lang, Operations Director, blang@sbnbcc.org Michael Dzierski, Finance Director, mdzierski@sbnbcc.org xii. Anticipated Completion Date: The anticipated completion date is May 31, 2025.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During the course of our eligibility testing, we noted one of the 45 selections where the individual was not part of the program during the fiscal year-under audit. The individual had been incorrectly included in the population, and in various reports for this program. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow for individuals to receive benefits who are not eligibility to participate in Federally funded programs. Additionally, these discrepancies may lead to incorrect Federal reporting. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
Show full finding ▾Hide full finding ▴Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During the course of our eligibility testing, we noted one of the 45 selections where the individual was not part of the program during the fiscal year-under audit. The individual had been incorrectly included in the population, and in various reports for this program. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines, or take into account specific requirements of Federal awards. Repeat Finding No. Effect NBCC’s lack of internal controls may allow for individuals to receive benefits who are not eligibility to participate in Federally funded programs. Additionally, these discrepancies may lead to incorrect Federal reporting. This may impact future funding from Federal awards. Recommendation We recommend NBCC establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that NBCC is managing the Awards in compliance with Federal statues and regulations, as well as the terms and conditions set forth in the specific Federal Award or subrecipient agreement.
xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to demonstrate this. However, the case manager neglected to exit the individual from HMIS during the previous audit period. This has been corrected. No services or funds were provided to this individual following their exit from the program. Our program has a good track record of data compliance and we expect this was an exception and not the rule. Program management will review and train staff again on data compliance during a weekly staff meeting, and will also counsel the involved staff member on the error to ensure there is no similar future error. xiv. Contact Person (s) Responsible for Corrective Action: Cassie Roach, Safe Parking Program Director, croach@sbnbcc.org Joel Goforth, Homeless Services Director, jgoforth@sbnbcc.org xv. Anticipated Completion Date: The anticipated completion date is April 30, 2025.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During our testing of the Organization’s payroll expenditures, we noted that for 16 of our 45 selections the employee’s time card had not been approved by the employee’s supervisor prior to submission for payroll processing, and recording in the GL. Cause of Condition The Organization’s internal controls are not properly designed and enforced to be in line with Federal guidelines, particularly, CFR 200.303. Effect of Conditions The Organization used Federal Awards for expenditures without proper supporting documentation and without obtaining and maintaining adequate approvals. Recommendation We recommend the Organization establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Organization is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award.
Show full finding ▾Hide full finding ▴Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Condition During our testing of the Organization’s payroll expenditures, we noted that for 16 of our 45 selections the employee’s time card had not been approved by the employee’s supervisor prior to submission for payroll processing, and recording in the GL. Cause of Condition The Organization’s internal controls are not properly designed and enforced to be in line with Federal guidelines, particularly, CFR 200.303. Effect of Conditions The Organization used Federal Awards for expenditures without proper supporting documentation and without obtaining and maintaining adequate approvals. Recommendation We recommend the Organization establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Organization is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award.
Management Response and Planned Corrective Action On occasion, given holidays, vacations, meeting schedules, etc., and the tight payroll submission timeline, it can happen that a timecard may be verbally approved but not signed and scanned when submitted for payroll processing and recording in the GL. Given the growth of the agency and the capacity of our administrative and accounting teams, we are in the process of transitioning to an online timecard process with a more robust payroll processing company. This should eliminate all timecard manual signature approval issues. This will be implemented by June 30, 2024. Views of Responsible Officials and Corrective Actions Management of NBCC agrees with the finding noted above, and will implement proper internal controls to correct the issue noted. Contact Information for Responsible Officials Kristine Schwarz, Executive Director, 805-963-7777
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
Finding 2022-01 ? Lack of Internal Controls (Significant Deficiency) Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states ?The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity?s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.? Condition During our testing of the Organization?s expenditures, we noted the following deficiencies in internal controls: 1. 3 of the 45 transactions selected for testing lacked sufficient and appropriate documentation to support the expenditure had been reviewed and approved. The 3 invoices were for office supplies. 2. 3 of the 13 employees selected for testing lacked a completed I-9 on file. Cause of Condition The Organization?s internal controls are not properly designed and enforced to be in line with Federal guidelines, particularly, CFR 200.303. Effect of Conditions The Organization used Federal Awards for expenditures without proper supporting documentation and without obtaining and maintaining adequate approvals. Recommendation We recommend the Organization establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Organization is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award.
Show full finding ▾Hide full finding ▴Finding 2022-01 ? Lack of Internal Controls (Significant Deficiency) Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states ?The non-Federal entity must: (a) 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. 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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity?s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.? Condition During our testing of the Organization?s expenditures, we noted the following deficiencies in internal controls: 1. 3 of the 45 transactions selected for testing lacked sufficient and appropriate documentation to support the expenditure had been reviewed and approved. The 3 invoices were for office supplies. 2. 3 of the 13 employees selected for testing lacked a completed I-9 on file. Cause of Condition The Organization?s internal controls are not properly designed and enforced to be in line with Federal guidelines, particularly, CFR 200.303. Effect of Conditions The Organization used Federal Awards for expenditures without proper supporting documentation and without obtaining and maintaining adequate approvals. Recommendation We recommend the Organization establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Organization is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award.
Management Response and Planned Corrective Action 1. While the current Internal Controls Manual allows for certain expenditures to be made with verbal and/or written approval from the Executive Director, the control does not state a dollar amount or specific circumstance for verbal approval and therefore the control has been clarified as follows: All funds to be expended must be approved by the Executive Director, either verbally or in writing, prior to the expenditure. Program staff may then request that the FA, OM or Administrative Associate purchase the needed expense either by debit card or credit card or produce a check for the ED?s signature. All requests for purchase must follow the same backup paperwork procedures outlined in the AP Procedures section. For all routine essential office supply individual item purchases $250 and under, the OM or FA has approval to make these purchases without ED verbal or written approval prior to the expenditure. All expenditures for individual items above $250 must be verbally approved by the ED prior to purchase and documented via email which then should be attached to the purchase documentation. Purchases $1,500 and above should follow the procurement policy outlined below in Control No. 21. In addition, the procurement control has been clarified with updated language as follows: For goods and services $1,499 and under, Executive Director approval is required as per the purchase policy above referenced in Control No. 17. 2. NBCC maintains an onboarding process and checklist which includes the completion of the I-9 for each employee. This process is strictly followed. The three employees identified during the testing that lacked a completed I-9 on file were for one employee who was hired during the initial period of the COVID lockdown when all processes were significantly impacted by the initial COVID quarantine, and the remaining two were onboarded by a staff member serving temporarily in the human resources position after the exiting human resources staff member did not return from a medical leave of absence. All current staff have completed I-9?s on file and there is every expectation that this control will continue to be enforced. As an additional guarantee of having a completed I-9 in place, NBCC has asked our external accounting firm, Vista Financial, to create an additional control where a new employee is not onboarded into Quickbooks for payroll without the completed I-9.
FAC accepted this audit on October 31, 2022 — management decision was due May 1, 2023.
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
FAC accepted this audit on October 4, 2022 — management decision was due April 4, 2023.
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