EIN: 910549511
UEI: MTJUMVZ415V6
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 5, 2021. 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 January 5, 2022 (1696 days ago).
What is a management decision? →The design of the internal controls over the Boys' and Girls' Clubs of Snohomish County?s (the Organization) federal awards for allowable costs charges costs up to the amount that is allowed in each federal award but excludes some of the costs to operate the federal program including indirect costs. Some non-payroll costs are recorded to federal programs using an after-the-fact determination that the cost was allowable. Costs not associated with federal programs were included in the accounting records which are not an accurate representation of actual expenses related to the federal program. Questioned Costs: None. Context: Additional procedures were required to determine the population of expenditures of federal awards that should be supported within the accounting software. We selected five employees out of population of 43 employees from the major program to test and noted no exceptions. From the initial population of the major program of non-payroll expenses, derived from the accounting software, three of the six transactions tested were improperly coded to the federal program. However, these three transactions were not reported to the governmental agency. We revised the population of non-payroll expenses using the 19 transactions reported to the governmental agency. From the revised population, we tested five transactions and noted no exceptions with the allowable costs reported to the governmental agency. An allocation method for indirect costs is not applied consistently to all federal and nonfederal programs. Indirect costs of $32,381 were charged to the major program, but not coded to the accounting software source code for the major program or a specific allocation methodology of the actual costs. Cause: Internal controls do not conform to allowable cost compliance requirements 2 CFR part 230, Cost Principles for Non-Profit Organizations (OMB Circular A-122 (A-122)), Appendix A to Part 230?General Principles, paragraph A. Basic Considerations, which establishes principles and standards for determining allowable direct and indirect costs for Federal awards. To be allowable under an award, costs must meet the following general criteria: ? Consistency?Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the organization. ? Be Accorded Consistent Treatment?A cost may not be allocated to an award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to an award as a direct cost. Effect: Allowable costs could be charged to federal awards without reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Recommendation: The Organization should implement written policies and procedures consistent with the COSO framework set forth by the CFR for internal controls and allowable costs. Further we recommend that that the method used to allocate indirect costs that have been incurred for common or joint objectives and cannot be readily identifiable with a particular final cost objective be documented. Views of Responsible Officials: Management?s response is reported in their ?Corrective Action Plan? included at the end of this report.
Show full finding ▾Hide full finding ▴Finding 2020-001: Internal Controls Significant deficiency in internal controls over compliance. Federal Agency: All Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) 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). Condition: The design of the internal controls over the Boys' and Girls' Clubs of Snohomish County?s (the Organization) federal awards for allowable costs charges costs up to the amount that is allowed in each federal award but excludes some of the costs to operate the federal program including indirect costs. Some non-payroll costs are recorded to federal programs using an after-the-fact determination that the cost was allowable. Costs not associated with federal programs were included in the accounting records which are not an accurate representation of actual expenses related to the federal program. Questioned Costs: None. Context: Additional procedures were required to determine the population of expenditures of federal awards that should be supported within the accounting software. We selected five employees out of population of 43 employees from the major program to test and noted no exceptions. From the initial population of the major program of non-payroll expenses, derived from the accounting software, three of the six transactions tested were improperly coded to the federal program. However, these three transactions were not reported to the governmental agency. We revised the population of non-payroll expenses using the 19 transactions reported to the governmental agency. From the revised population, we tested five transactions and noted no exceptions with the allowable costs reported to the governmental agency. An allocation method for indirect costs is not applied consistently to all federal and nonfederal programs. Indirect costs of $32,381 were charged to the major program, but not coded to the accounting software source code for the major program or a specific allocation methodology of the actual costs. Cause: Internal controls do not conform to allowable cost compliance requirements 2 CFR part 230, Cost Principles for Non-Profit Organizations (OMB Circular A-122 (A-122)), Appendix A to Part 230?General Principles, paragraph A. Basic Considerations, which establishes principles and standards for determining allowable direct and indirect costs for Federal awards. To be allowable under an award, costs must meet the following general criteria: ? Consistency?Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the organization. ? Be Accorded Consistent Treatment?A cost may not be allocated to an award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to an award as a direct cost. Effect: Allowable costs could be charged to federal awards without reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Recommendation: The Organization should implement written policies and procedures consistent with the COSO framework set forth by the CFR for internal controls and allowable costs. Further we recommend that that the method used to allocate indirect costs that have been incurred for common or joint objectives and cannot be readily identifiable with a particular final cost objective be documented. Views of Responsible Officials: Management?s response is reported in their ?Corrective Action Plan? included at the end of this report.
Corrective Action Plan For the Year Ended December 31, 2020 Planned Implementation of Correction Action: By December 31, 2021 Person Responsible for Corrective Action: Gulia Saville, Director of Finance, gsaville@bgcsc.org We have developed new policies and procedures to ensure improved internal control related to allocation method for indirect costs, and consistency to all federal and non-federal programs. The indirect allocation method will be used to allocate indirect costs that have been incurred for common or joint objectives and cannot be readily identifiable with a particular final cost objective will be documented. Finding 2020-001 We will determine, based on its own unique combination of staff, facilities, and experience how to assure proper and efficient administration of the federal funds. The cost will be consistent with policies, regulations, and procedures that apply uniformly to both federal awards and other activities. BGCSC will not apply different rules for allowable costs based on funding source. Once the cost has been determined to be allowed, it must be allocable. Charges to federal awards will be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. All allocations will flow through accounting system. Reasonably reflect the total activity for which the employee is compensated, not exceeding 100% of compensated activities. Administrative personnel who provide supervision related to grants, support grant related activities such as data entry, payroll, reports, invoicing, grant reporting, preparation of financial document such as reimbursement claims, etc. will be allocated as a percent of salary. Documentation records will be adjusted in a timely manner if there are significant changes in the employees work activity. All necessary adjustments will be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
FAC accepted this audit on July 19, 2018 — management decision was due January 19, 2019.
GSA_MIGRATION
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