Bill Wilson CenterNon-Profit

SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS MATERIAL WEAKNESS COMPLIANCE 2024-007 – MISSING DOCUMENTS AND ALLOWABLE COSTS IDENTIFICATION OF THE FEDERAL PROGRAM ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds CRITERIA An organization must have a system in place to properly secure and have the ability to retrieve critical documents. Grant revenue should be billed and recognized based on accurate and eligible costs, milestones, or the satisfaction of certain conditions. CONDITION During our testing, we noted the following: 1. Management was unable to provide supporting documents for claimed expenses of $37,007. 2. Management was able to provide advance request forms. 3. There were $76,273 of ineligible costs. CAUSE Management did not secure the documents in a central location that is accessible to those who need access. The costs incurred were not properly reviewed to eliminate ineligible costs or the billing to grantors was not reviewed. Accurate and timely monthly grant billing procedures were not performed. EFFECT The effect for missing documents is that key financial statement amounts will not be supported. The inability to produce appropriate supporting documents will lead to questioned costs or produce inconsistent results. Ineligible costs will lead to inaccurate financial statements for revenue and receivables. Also, claiming ineligible costs could jeopardize future funding or place the Organization in a negative position with the funder. QUESTION COSTS $37,007 for missing documents. $76,273 for ineligible costs. RECOMMENDATION Management should develop a system to store and categorize electronic and paper documents so that they can be easily accessible. Management has policies in place for billing; however, more attention is required when reviewing expenses being charged to a respective awards. Training on eligible costs should be provided to program and accounting staff. MANAGEMENT’S RESPONSE AND PLANNED CORRECTIVE ACTION See attached corrective action plan

IDENTIFICATION OF THE FEDERAL PROGRAM ALN 16.575 Crime Victim Assistance CRITERIA An eligible participant in this program is an individuals aged 18 to 25. CONDITION Management was not able to provide support for all of the participants tested. Accordingly, we were not able to determine eligibility. CAUSE Management did not monitor eligibility on a consistent basis and maintain appropriate supporting documentation to support participant eligibility. The costs and activity were not properly reviewed against eligible participants or the billing to grantors was not reviewed. Accurate and timely monthly grant billing procedures were not performed. EFFECT Certain key financial statement amounts are not supported. The inability to produce documents could lead to questioned costs or produce inconsistent results which could impact the ability to receive future funding. QUESTION COSTS $17,562. RECOMMENDATION Management should develop a system to store and categorize electronic and paper documents so that they can be easily accessible. Management should create a template of the eligibility requirements for each grant. As part of the grant billing process, management should review the billing support for eligible participants and costs. More care is required to be exercised when reviewing eligibility and costs charged on grants. Training should be provided to program and accounting staff.   SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (CONTINUED) MATERIAL WEAKNESS COMPLIANCE 2024-008 – ELIGIBILITY (CONTINUED) MANAGEMENT’S RESPONSE AND PLANNED CORRECTIVE ACTION See attached corrective action plan.

Finding 2020-001 U.S. Department of Housing and Urban Development CFDA 14.267 and 14.231 Criteria: Non-Federal entities are prohibited from hiring or contracting with suspended or debarred parties in covered transactions. As defined in 2 CFR section 180.995 and agency adopting regulations, prior to entering into transactions with an entity or individual, the nonfederal entity must verify that the entity or individual is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we inquired with management regarding their policy relating to suspended or debarred vendors or individuals and identified that the Organization has a policy in place relating to verifying that employees of a specific program type are not suspended or debarred on a monthly basis. The Organization also has a current procedure for searching the OIG website to verify all employees are not suspended or debarred on a monthly basis. The Organization does not have a policy or procedure to verify that vendors are not suspended or debarred or otherwise excluded from participating in the transaction prior to entering into a covered transaction. Context: A policy relating to suspended or debarred vendors or individuals provides guidance and requirements that must be followed for covered transactions, but specifically transactions related to Federal awards. Cause: The policies and procedures relating to setting up new vendors does not include verification that the vendors are not suspended or debarred. Effect: The Organization may have used funds to hire or purchase services or supplies from suspended or debarred individuals or entities. Recommendation: The Organization should develop, adopt and implement policies and procedures related to verification that new vendors are not suspended or debarred. The procedures should include the maintenance of supporting documentation related to the conclusion that vendors are not suspended or debarred. The procedures should also include a periodic check for existing vendors to verify that vendors have not been subsequently suspended or debarred. Questioned Costs: Unknown. Views of Responsible Officials and Planned Corrective Actions: Bill Wilson Center agrees with the finding and has a taken steps to rectify the finding. See the Corrective Action Plan on page 46 for further detail.