Colorado Coalition Against Domestic ViolenceNon-Profit

Finding 2024-001: 93.591 - U.S. Department of Health and Human Services - Family Violence Prevention and Services/State Domestic Violence Coalitions Reporting, Non-Compliance Criteria: Federal Financial Reports are due to the U.S. Department of Health and Human Services under provisions of the grant within 90 days after the reporting period end date. Condition: The Federal Financial Reports were not filed in a timely manner. Effect: Failure to submit reports on time may cause delay of the program funding. Questioned Costs: None. Cause: The Organization did not submit the Federal Financial Reports on time. _x000C_Recommendation: We recommend that the Organization review its procedures to ensure reports are remitted on time in accordance with the terms outlined by the agreement.

Finding 2024-002: 93.591 - U.S. Department of Health and Human Services - Family Violence Prevention and Services/State Domestic Violence Coalitions Procurement and Suspension and Debarment, Non-Compliance Criteria: Per 2 CFR § 200.318(a), non-Federal entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, policies must address standards of conduct, competition, cost analysis, and methods of procurement. Condition: During the review of the Organization’s procurement procedures, it was noted that the Organization does not have an updated, written procurement policy that reflects the requirements outlined in 2 CFR § 200.318 – 200.327. The current policy on file predates the implementation of the Uniform Guidance and does not incorporate key standards such as micro-purchase thresholds, competitive bidding requirements, or conflict of interest provisions. Effect: Without an updated procurement policy that aligns with federal requirements, the Organization is at risk of noncompliant procurement practices. This could lead to unallowable costs being charged to federal awards, and potentially jeopardize future funding. Questioned Costs: None. Cause: The Organization has not reviewed or revised its procurement policy since the adoption of the Uniform Guidance, resulting in outdated internal procedures. _x000C_Recommendation: The Organization should update its procurement policy to fully align with the procurement standards outlined in 2 CFR § 200.318 through § 200.327. Staff responsible for procurement should also be trained on the updated procedures to ensure consistent and compliant practices.

Finding 2024-003: 93.591 - U.S. Department of Health and Human Services - Family Violence Prevention and Services/State Domestic Violence Coalitions Allowable Costs/Cost Principles, Significant Deficiency in Internal Control and Noncompliance Criteria: According to 2 CFR § 200.302(b)(5), non-federal entities must have written procedures to ensure that expenditures are in accordance with the terms and conditions of the federal award. Furthermore, entities are expected to compare actual expenditures with budgeted amounts for each federal award. Condition: During our audit, we noted that the Organization does not maintain or regularly review a budget-to-actual comparison for expenditures charged to the federal grant. As a result, management is unable to assess whether spending is aligned with the approved grant budget. Effect: Failure to monitor expenditures against the approved grant budget increases the risk of unallowable costs, budget overruns, and noncompliance with grant terms, which may result in questioned costs or potential repayment of funds. Questioned Costs: None. Cause: The Organization has not established internal procedures or systems to monitor grant expenditures against the approved budget. _x000C_Recommendation: We recommend that the Organization implement a process to compare actual expenditures to the approved grant budget on a regular basis. This may include monthly or quarterly reviews by program and finance staff to ensure expenditures remain within approved categories and thresholds. Documentation of such reviews should be maintained to demonstrate compliance.

Finding 2024-004: 93.591 - U.S. Department of Health and Human Services - Family Violence Prevention and Services/State Domestic Violence Coalitions Allowable Costs/Cost Principles, Material Weakness in Internal Control and Noncompliance Criteria: In accordance with 2 CFR §200.403(g), costs must be adequately documented in order to be allowable under a federal award. Additionally, per 2 CFR §200.302(b)(3), recipients must maintain records that identify the source and application of funds for federally funded activities. Furthermore, effective internal controls per 2 CFR §200.303 require that transactions be properly authorized and reviewed to ensure compliance with applicable requirements. Condition: During our testing of expenses charged to the federal award, we reviewed a sample of 10 transactions totaling $9,284. Of those, 7 transactions (representing $8,980) were found to be noncompliant due to one or both of the following: • Missing supporting documentation, such as receipts or invoices • Missing approval documentation, such as required supervisor sign-offs These issues impaired our ability to determine whether the expenses were allowed, reasonable, and allocable under the terms of the award. Due to the high rate of errors, we performed extrapolation procedures over the population of similar expenses totaling $107,782. Based on the sample error rate and our extrapolation methodology, we estimate that $36,846 of the total expenses charged to the federal award may be unallowable and are thus considered extrapolated questioned costs. Effect: As a result of insufficient supporting and approval documentation, the allowability of a significant portion of expenses charged to the federal award could not be determined. This has led to an extrapolated questioned cost of $36,846. Questioned Costs: $36,846 (extrapolated) Cause: The deficiencies noted appear to be the result of weak internal controls related to documentation and approval workflows for federal expenditures. Specifically, the Organization does not appear to have a consistent process to: • Ensure documentation is retained for all expenses • Verify and record supervisory or grant-related approvals Recommendation: We recommend the Organization take immediate steps to improve internal controls related to documentation and record retention for federal program expenditures. The Organization should ensure that all expenses charged to the federal award are supported with adequate documentation. Additionally, the Organization should also ensure approvals are properly documented regardless if the expense is paid by check or electronic payment.