BENTON FRANKLIN COMMUNITY ACTION COMMITTEE

EIN: 910792238

UEI: Z24FW5AN4BM1

9
Audit Years
8
Total Findings
3
Repeat Findings

FY 2024-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 1, 2025. 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 June 1, 2026, which was (79 days ago).

What is a management decision? →
2024-002
Activities Allowed or Unallowed
REPEATMATERIAL WEAKNESSQUESTIONED COSTS
Condition

Program: All Criteria: Charges to grants require proper authorization, clear connection to project activities, reasonable cost, and documentation of payroll hours that reflects employee time and effort. Condition: Reallocations of wages and related expenditures were made on occasion without documentation that both supported the change and approved the change. The adjustments made to wages similarly impacted cost allocations based on wages. Context: The condition was noted during our testwork over the Organization’s expense transactions. Effect: Costs charged to programs did not always correspond with the time and effort documented by the employee and approval by the manager. Cause: Prior accounting staff periodically adjusted costs charged to programs without maintaining sufficient documentation detailing the nature of the changes. This resulted in the time documented by employees in timecards and approved by a manager not corresponding with the entry in the accounting system. Recommendation: If any adjustments are deemed necessary to an employee time-card, the change should be documented, and approval of the change present to support the changes. Questioned Costs: Undeterminable View of Responsible Officials: BFCAC made a change in personnel during 2024. Subsequently, BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

Corrective Action Plan

BFCAC made a change in personnel during 2024. Subsequently, BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

Prior Finding References

2022-001, 2023-002

About Activities Allowed or Unallowed →

FY 2023-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 13, 2025. 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 November 13, 2025, which was (279 days ago).

What is a management decision? →
2023-002
Activities Allowed or Unallowed
REPEATMATERIAL WEAKNESSQUESTIONED COSTS
Condition

Condition: Reallocations of wages and related expenditures were made on occasion without documentation that both supported the change and approved the change. The adjustments made to wages similarly impacted cost allocations based on wages. Criteria: Charges to grants require proper authorization, clear connection to project activities, reasonable cost, and documentation of payroll hours that reflects employee time and effort. Cause: Time charged by employees to time cards and approved by a manager did not in all cases correspond with the entry in the accounting system. Effect: Time charged to programs are not always supported by a corresponding tracking of time and effort by the employee and approval by the manager. Recommendation: If any adjustments are deemed necessary to an employee time card, updated approved documentation should be present to support the changes. Questioned Costs: Undeterminable

Corrective Action Plan

BFCAC made a change in personnel during 2024. Subsequently BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

Prior Finding References

2022-001

About Activities Allowed or Unallowed →

FY 2022-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 27, 2023. 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 March 27, 2024, which was (875 days ago).

What is a management decision? →
2022-001
Activities Allowed or Unallowed / Cost Allowability
REPEATMATERIAL WEAKNESSQUESTIONED COSTS
Condition

Department of Housing and Urban Development Department of Health and Human Services Material Weaknesses Condition: Multiple reallocations of salaries and related expenditures were not supported by underlying approved timesheets used to document the allocation basis for the allocation of salaries and related expenditures. Criteria: The reallocations were made via journal entries in which no additional supporting documentation was present to justify the reallocation of expenditures. Cause: Journal entries were used to reallocate salaries and related expenses without justification documentation and journal entries recorded were not reviewed or approved by someone other than the person authorized to record the journal entry. Effect: Because of the failure to follow BFCAC?s policy of allocating salaries and related expenditures based on time charged and documented, expenditures were reallocated with no justification or documentation to support the reallocation. Recommendation: BFCAC needs to consistently follow its allocation methodology regarding salaries and related expenditures which allocates these expenditures based on supporting approved timesheets for hours worked. If any adjustments are deemed necessary, approved documentation should be present to support the changes and the journal entries should be reviewed and approved by the approving program manager or executive director. Questioned Costs: Undeterminable

Corrective Action Plan

2022-01* Our Finance Director (FD) created a tracking form for Journal Entries which included back-up materials on September 27, 2022. FD started using the form to create a trail and continued through mid-January 2023, at that time the FD started using the form that the Executive Director (ED) created. There was a miss commination between the audit reviewer and the FD. Some of these transactions were signed off and some were not. Consistency with the signing was the major problem, but the FD did review with the ED/and or COO/IT during the billing process. Process has been implemented that when adjustments are deemed necessary, approved documentation will be present to support the changes and the journal entries will be reviewed and approved by the department director or executive director. *Responsible person: Judith Gidley, Executive Director

Prior Finding References

2021-002

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-002
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

Department of Housing and Urban Development Department of Health and Human Services Material Weaknesses Condition: Multiple reallocations of salaries related expenditures and benefits that are allocated based on time were not supported by underlying approved timesheets used to document the allocation basis for the allocation of salaries and related expenditures. Criteria: The allocations are made based on the time distributions updated each payroll period to reflect the time recorded on the reviewed and approved timesheets. Cause: The allocations are recorded based on distribution table data updated each time a new payroll is processed. As a result, if the salaries and related expenditures cost allocations are not recorded on a timely basis the appropriate distribution table data will not reflect the appropriate payroll period data and the error will not be detected by the current internal control structure. Effect: Due to the untimely recording of salaries and related expenditures based on time, the expenditures allocated for the various programs are based on the incorrect supporting time data. Recommendation: BFCAC needs to implement internal control procedures to ensure that allocated salaries and related expenditures are recorded on a timely basis and reflect the appropriate supporting distribution allocation time data. Questioned Costs: Undeterminable

Corrective Action Plan

2022-02* BFCAC will implement internal control procedures to ensure that allocated salaries and related expenditures are recorded on a timely basis and reflect the appropriate supporting distribution allocation time data *Responsible person: Judith Gidley, Executive Director

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-003
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

Department of Housing and Urban Development Material Weaknesses Condition: The internal controls over eligible recipients? rental assistance payments did not detect that the client received the incorrect subsidy amounts due to income changes not being verified at the time of notification from the client and/or having the incorrect subsidy amount be paid to the applicable landlord. Criteria: Internal controls should be in place to ensure that all eligible recipients receive the appropriate level of rental subsidy based on the income calculation supported by income documentation provided by clients Cause: Internal control policies did not include procedures for verifying that all income change information data received from supported clients is captured in the client files and rental subsidies adjusted for supportive payments made to applicable landlords. Effect: The lack of internal controls led to clients receiving incorrectly calculated subsidy payment amounts. Recommendation: BFCAC should adopt internal control procedures to ensure that all supporting income documentation provided by clients is reevaluated and subsidy amounts adjusted and that approved landlord vendor payments reflect the updated subsidy amounts.

Corrective Action Plan

2022-03* BFCAC has adopted internal controls to ensure that all supporting income documentation provided by clients is reevaluated and subsidy amounts adjusted and that approved landlord vendor payments reflect the updated subsidy amounts. The following processes has now been formalized and implemented regarding the following: ? Initial Income Calculation ? Income changes (up or down) ? Re-Certification ? Household size (up or down) ? Documentation Review ? Utility Allowance (up or down) ? Rental Increase Any and all changes listed above require a file review and sign off by either the Program Manager or the Housing Department Director prior to payment authorization. *Responsible person: Judith Gidley, Executive Director

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2021-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on January 22, 2023. 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 July 22, 2023, which was (1124 days ago).

What is a management decision? →
2021-001
Other
MATERIAL WEAKNESS
Condition

Material Weaknesses Condition: Significant related party transaction was entered into with a key employee in violation of BFCAC?s conflict of interest policies during the year ended December 31,2021. Criteria: Internal controls should be in place to ensure that any transaction executed by BFCAC should be evaluated for related party relationships and conflicts of interests by BFCAC board of directors and employees. Cause: Conflict of interest policies in place regarding related party transactions were not followed. Effect: Because of the failure to follow the conflict of interest polices regarding related party transactions a sale of property to a key employee was not detected or communicated to the board of directors until year end audit procedures detected the sale. The sale involved a home and related property with a total sales price of $225,000 and a realized loss on the sale of $394,420. Recommendation: Conflict of interest policies for BFCAC be reviewed and a step-by-step process be adopted for evaluating all transactions entered by BFCAC to ensure conflicts of interest and related party transactions are recognized. The policy should include the evaluation and determination be made for all transactions to ensure policy compliance. The policy should also outline the evaluation process for all employees and board members and a process in which a possible conflicts and relationships be communicated to those in charge of approval of transactions and those charged with governance.

Corrective Action Plan

2021-01 BFCAC staff will develop an expanded internal conflict of interest and related party transactions policy for the Board of Director to adopt that includes a step-by-step process for the evaluation and determination to be made for all transactions that will ensure compliance and will be signed by all employees. BFCAC determined that all employees must sign the `Conflict of Interest? Form yearly. BFCAC?s staff meeting on November 16, 2022, accomplished having all staff sign the form. All management staff and Board members will sign the `Conflict of Interest? Form on the first meeting in January and are kept on file. The Owen Street property was sold with board approval. BFCAC realizes this transaction resulted in the loss to BFCAC but found it to be in the best interest of BFCAC to sell the property as quickly as possible to mitigate additional expense and financial losses.

About Other →
2021-002
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESS
Condition

Material Weaknesses Condition: Multiple reallocations of salaries and related expenditures were not supported by underlying approved timesheets used to document the allocation basis for the allocation of salaries and related expenditures. Criteria: The reallocations were made via journal entries in which no additional supporting documentation was present to justify the reallocation of expenditures. Cause: Journal entries were used to reallocate salaries and related expenses without justification documentation and journal entries recorded were not reviewed or approved by someone other than the person authorized to record the journal entry. Effect: Because of the failure to follow BFCAC?s policy of allocating salaries and related expenditures based on time charged and documented, expenditures were reallocated with no justification or documentation to support the reallocation. Recommendation: BFCAC needs to consistently follow its allocation methodology regarding salaries and related expenditures which allocates these expenditures based on supporting approved timesheets for hours worked. If any adjustments are deemed necessary, approved documentation should be present to support the changes and the journal entries should be reviewed and approved by the approving program manager or executive director. Questioned Costs: Undeterminable

Corrective Action Plan

2021-02 BFCAC?s Executive Director has reviewed the agency?s Financial Policies and Procedures and will conduct hands-on refresher training for the Finance Director, accounting staff, and all department directors. All future Journal Entries submitted for correction will be signed off by the Executive Director or the Department Director for whose program is affected by the requested change. All staff will follow the approved Financial Policies and Procedures when processing timesheets.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-003
Special Tests & Provisions
Condition

Condition: During the year ended December 31, 2021, BFCAC had one of its low-income representative board member positions vacant. Criteria: Program requires that the board of BFCAC be made up of board members in a ratio that represents equal representation for the three following populations: ? One-third of the members be elected representatives in the community or their designee (the elected official must be holding office on the date of the selection). There is a provision that allows for appointed government officials, or their designee, to be counted in meeting this requirement. ? Not fewer than one-third of the board members are chosen in a democratic selection process adequate to assure that these members of the board are representative of the low-income individuals and families served. Additionally, each low-income representative must reside in the neighborhood served. ? The remaining board members are officials and members of business, industry, labor, religious, law enforcement, education, or other major groups and interests in the community served. Cause: Due to COVID, filling the position was difficult and no replacement board member was available to fill the position. BFCAC?s by-laws outline that the required board make-up be in line with program requirements, but BFCAC was unable to find a replacement to fill the position. Effect: BFCAC is out of compliance with the board make up requirements outlined for the program. Recommendation: BFCAC continue to follow its adopted policies regarding board make-up compliance and continue to work to fill the low-income board position. Questioned Costs: None

Corrective Action Plan

2021-03 CAC has replaced the low-income representative since the audit started and is working on the public positions. CAC will continue to follow our by-laws.

About Special Tests and Provisions →

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