THE NW NETWORK OF BISEXUAL, TRANS, LESBIAN AND GAY SURVIVORS OF ABUSENon-Profit

Criteria: The Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its procurement process. In addition, Section 200.318-326 of the Code of Federal Regulation (CFR) states that all procurement transactions must be conducted in a manner providing full and open competition. A non-Federal entity must have written policies and procedures on procurement, which should define required approvals for purchases and thresholds for each procurement method defined under Section 200.320. Moreover, Section 200.318(i) of the CFR states that a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Section 200.333 of the CFR states that financial records, supportingdocuments and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report. It also states that a non-federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Award recipients must not utilize any vendor which is suspended ordebarred or is otherwise excluded from the central contractor registry.Condition and Context: The Organization has an approved procurement policy in place that is in line with CFR requirements, but the policy was not being implemented. During our testing of two procurement transactions that exceeded the micro-purchase threshold, totaling $36,990, we noted that the Organization did not maintain documentation to support the vendor selection process and compliance with its policies and procedures for the two transactions tested. In addition, evidence of verification that a prospective contractor is not on the US Government Office of Federal Contracts Compliance Programs Debarred or Suspended list was not maintained for these transactions.Questioned Costs: Although the two procurement transactions tested totaled $36,990, total questioned costs are unknown because we were not able to determine whether the procurement was made in full and open competition.Cause: Due to personnel and management turnover, the Organization could not locate procurement documentation of the procurement transactions.Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-001 in the 2019 report.Effect: Failure to obtained vendor solicitation for procurements above small purchase acquisition threshold and failure to maintain proper documentation for vendor selection process is noncompliance with federal regulations and the Organization?s policy.Auditor?s Recommendation: We recommend that the Organization follow its procurement policy and retain documentation to support the procurement and verification regarding suspension and debarment.Management?s Response: The Organization agrees with the finding and a new process implemented in late2021 has been developed to rectify the issue.

Criteria: The Organization is responsible for establishing and maintaining a system of internal control that should include controls over maintaining relevant supporting documentation to adequately demonstrate that transactions charged to federal awards are both allowable and reviewed and approved by an appropriate individual.Condition and Context: The Organization?s policy and internal control over cash disbursements requires that relevant supporting documentation, such as the invoice, be maintained and reviewed and approved by an appropriate individual. During our testing of 25 non-payroll cash disbursement transactions, we noted that for three transactions totaling $556 the invoice or similar support, as well as evidence of review and approval, could not be provided. For eight additional transactions, while the invoice or similar support was available, the review and approval process was not documented.Questioned Costs: Known questioned costs were $556 of charges that it was unknown whether they were over or under charged. Likely questioned costs are believed to be below the questioned costs threshold.Cause: Due to personnel and management turnover, the Organization could not locate relevant documentation for these transactions. For the eight additional transactions, these are recurring auto-pay transactions which are to be reviewed and approved as part of the monthly bank reconciliation process. However, the review and approval of the monthly bank reconciliation was not documented Repeat Finding: This is not a repeat finding.Effect: Inadequate records for cash disbursements presents a reasonable possibility that disbursements are inaccurate and inappropriately applied to the federal award.Auditor?s Recommendation: We recommend that the Organization consistently follow its document retention policy and retain documentation to evidence that the review and approval process has occurred.Management?s Response: The Organization agrees with the finding and a new process implemented in late 2021 has been developed to rectify the issue.

Criteria The Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its procurement process. In addition, Section 200.318-326 of the Code of Federal Regulation (CFR) states that all procurement transactions must be conducted in a manner providing full and open competition. A non-Federal entity must have written policies and procedures on procurement, which should define required approvals for purchases and thresholds for each procurement method defined under Section 200.320. Moreover, Section 200.318(i) of the CFR states that a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Section 200.333 of the CFR states that financial records, supporting documents and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report. It also states that a non-Federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition In 2018, the Northwest Network approved a procurement policy that is in line with the requirements of 2 CFR ? 200.317 ? 200.326, however, the policy was not being implemented. During our testing of three procurement transactions that exceeded the micro-purchase threshold, totaling $153,053, we noted that The Northwest Network did not maintain documentation to support the vendor selection process and compliance with its policies and procedures for all the three transactions tested. In addition, evidence of verification that a prospective contractor is not on the US Government Office of Federal Contracts Compliance Programs Debarred or Suspended list was not maintained for these transactions. Cause Due to personnel and management turnover, The Northwest Network could not locate procurement documentation of the procurement transactions. Effect Failure to obtain vendor solicitation for procurements above small purchase acquisition threshold and failure to maintain proper documentation for vendor selection process is noncompliance with Federal regulations and the Organization?s policy. Context The total population for procurement testing was $247,050 and the three procurement transactions reviewed accounted for $153,053 of that population. Questioned Costs: $153,053 Repeat Finding This is a repeat finding from prior year. This was reported as finding 2018-003 in the 2018 report. Recommendation: We recommend that The Northwest Network follow its procurement policy and retain documentation to support the procurement and verification regarding suspension and debarment. Views of Responsible Officials: The Northwest Network agrees with the finding and a new process implemented in late 2021 has been developed to rectify the issue.

Criteria The Northwest Network is responsible for establishing and maintaining a system of internal control that should include controls to ensure compliance with matching, level of effort, and earmarking requirements of federal awards Condition The Northwest Network policy and internal control over matching of federal awards requires the Finance and Program Directors determine match, level of effort or earmarking requirements and the allocation between different grants and other funding. During our testing over five grants under the CFDA 16.575 program, we noted that the five grant programs had matching requirements totaling $292,793, however, The Northwest Network could not provide supporting documentation on how the matching requirements were met for all the five grant programs. Cause Due to personnel and management turnover, and lack of policies and procedures on compliance with matching requirements, The Northwest Network was not able to identify matching requirements of the five programs and was not able to provide adequate documentation on how the matching requirements were met. Failure to identify matching requirements and failure to maintain proper documentation on how grant matching requirements were met is noncompliance with Federal regulations, grant award requirements and the Organization?s policy and Federal payment of unmatched funds . Questioned Costs: $292,793 Recommendation: We recommend that The Northwest Network implement policies and procedures to ensure compliance with the matching, level of effort and earmarking requirements and retain documentation to support grant matching requirements were complied with. Views of Responsible Officials: The Northwest Network agrees with the finding. In 2021, The Northwest Network implemented and developed policies and procedures to comply with grant matching requirements. Due to the new process implemented, The Northwest Network was able to provide sufficient documentation on how matching requirements were met.

Criteria The Organization is responsible for establishing and maintaining a system of internal control that should include controls over cash management of federal funds. Condition The Northwest Network policy and internal control over cash management of federal funds requires that federal fund draw request should be reviewed and approved by Finance Director. During our testing of six federal fund drawdowns, we noted that the support for the approval of two drawdown requests could not be provided; however, this situation did not result in any noncompliance with cash management compliance requirements. Cause Due to personnel turnover, The Northwest Network could not locate approval of drawdown request Context and Effect Inadequate controls over cash management of Federal funds presents a reasonable possibility that drawdowns of federal funds are inaccurate and inappropriate. Questioned Costs Could not be determined Recommendation: We recommend that The Northwest Network implement policies and procedures to obtain and retain the necessary documentation related to the review and approval of federal fund drawdowns. The Northwest Network agrees with the finding and a new process implemented in late 2021 has been developed to rectify the issue.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION