Colorado Humanities

Information on the Federal Program: CFDA 45.129?Promotion of the Humanities-Federal-State Partnership, National Endowment for the Humanities Award Number: SO-263595-19. Compliance Requirements: Matching, Level of Effort, Earmarking. Type of Finding: Significant deficiency, non-compliance. Criteria: Program requirements state that matching contributions on a dollar for dollar basis of funds drawn are required to be made by the end of the fiscal year. Outright funds can be matched from cash contributions or in-kind contributions. The regulations in 2 CFR 200.306 indicate that in-kind contributions require verifiable from the non-Federal entity's records. Condition: For the year ended October 31, 2019, we reviewed the in-kind contributions counted toward the matching requirement and noted that certain contributions did not have supporting documents in their records. Cause: While controls were put in place to ensure all in-kind contributions were supported by written documentation, the controls were not operating consistently during the period to ensure all in-kind contributions had adequate documentation to support the amount reported by the non-Federal entity. Effect or Potential Effect: Ultimately, all items selected for testing were verified directly with the donors. The failure to put adequate controls in place to ensure all contributions are appropriately supported could result in in-kind contributions being reported that are not verifiable. Questioned Costs: None. Context: Of the 40 in-kind contributions tested, 5 lacked supporting documentation at the time the contribution was made. Documentation was obtained and provided for all 5 items at the time the items were selected for testing. Recommendation: The entity program staff and management should review controls in place that ensure in-kind contributions used in the match calculation are supported at the time contributions are made are operating consistently for all contributions recorded on their in-kind tracking records. The entity should consider adding an additional column on these records to include confirmation that adequate support has been obtained. Responsible Official's Response and Corrective Action Planned: Management of Colorado Humanities concurs with the FY2019 audit finding. While all staff members charged with documenting in-kind contributions consistently request confirmation from donors, there has been inconsistent follow-up to ensure that the documentation was received. We will add a check-off column to the in-kind summary spreadsheet and the staff member charged with making spreadsheet entries will not accept in-kind documentation from other staff unless donor confirmation is included. We also will review in-kind documentation procedures with all staff. Planned Implementation Date of Corrective Action: June 2020. Person Responsible for Corrective Action: Executive Director.