Audit of Selected Internal Controls at Central Virginia Legal Aid Society, Inc

Report Information

Date Issued
Report Number
AU20-02
Report Type
Audits
Joint Report
Yes
Participating OIG
Legal Services Corporation OIG
Agency Wide
No (location specific)
Location(s)

RIchmond, VA
United States

Questioned Costs
$7555
Funds for Better Use
$0

Recommendations

Date Issued

Ensure the accounting system provides an audit trail to present an accurate and traceable allocation report and transaction for each funding source.

Date Issued

Ensure that CVLAS staff complies with written policies and procedures for cost allocation. Any deviation from the written cost allocation formula should be documented on file.

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Ensure that cost allocations are reviewed for the previous month, monitor expenditures, and make adjustments for funding sources. Perform cost allocations more than once per year.

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Ensure that the cost allocation process is performed frequently enough to provide meaningful financial information to grantee management, the Board of Directors, and funders.

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Ensure that allocations are performed for rental income pursuant to 45 CFR Section 1630.17 and in accordance with the written procedures in CVLAS Accounting Manual; any deviation should be documented on file.

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Assign the corresponding funding source within the case management system and ensure that the requirements of 45 CFR Section 1609.4(b) are fully implemented.

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Ensure that an accurate and complete attendance record (i.e., timesheet) is maintained for each employee for each pay period.

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Conduct a detailed review of all payroll processed in 2018 and 2019 to identify payroll over and underpayments and complete this review within six months of the issuance of this report.

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To the extent consistent with the law, reimburse employees that were identified as underpaid and attempt to recover payment from all employees that were identified as overpaid in the above review.

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Ensure that employees assigned with payroll duties receive the appropriate training to ensure that payroll is accurately documented, recorded, processed, and reported.

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Ensure that attendance records such as timesheets for all employees are approved by the employee's supervisor and documented on file.

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Ensure that advance approvals for compensaory time are adequately documented to reflect that the request was made prior to an employee performing overtime duties.

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Ensure that compensatory time is only awarded to employees who work more than 45 hours in a given week per the CVLAS Personnel Manual

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Establish a formal tracking system to record employees' compensatory time earned, used, and remaining balances.

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Ensure that compensatory time is accurately recorded in the payroll system, in the corresponding payroll register, and subsequently reported on the employee's pay stub.

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Ensure that LSC unallowable costs are charged to funding sources other than LSC and reflected within the financial software to provide an audit trail.

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Ensure that supporting documentation, including receipts and invoices, are maintained for each transaction to fully support all credit card purchases.

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Ensure the purchase approval process is followed and appropriate approvals are obtained for each requisite transaction. These approvals should be documented and maintained on file.

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Ensure that credit cards are not being shared and only those individuals specifically named as authorized credit card users in the CVLAS Accounting Manual have access to a CVLAS credit card.

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Require a signed user acknowledgement agreement for each authorized credit card user. The form should include repayment terms and conditions for personal use or misuse of the card and be documented on file.

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Ensure that review and approval processes are adequately documented with signature and date prior to disbursements.

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Ensure that disbursements are not made without adequate documentation and internal verification of receipt of goods and accuracy of invoices.

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Remove accounting system access from anyone who is not a current authorized user of the CVLAS accounting system. The Executive Director should also implement a policy whereupon user access to the accounting system is immediately removed upon termination…

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Ensure that anyone who accesses the accounting system has their own unique username and password. The Executive Director should limit user privileges to ensure that users have access only to those functions pertinent to their duties.

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Ensure that authorized individuals perform bank reconciliations monthly and no later than 15 working days after receipt of the statement per CVLAS Accounting Manual.

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Ensure bank reconciliations are reviewed and approved by a responsible individual including signature and date by the preparer and approver.

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Ensure the Fiscal Administrator signs and dates their approval of petty cash reconciliations on the reconciliation form.

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The Executive Director should ensure that CVLAS complies with the requirements of the LSC Accounting Guide 3-5.16 and ensure that contracts and invoices are received, documented, approved and verified prior to payment.

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Ensure property records contain all elements required by the LSC Accounting Guide 3-5.4 as mentioned above and that all employees involved in performing inventories and maintaining property records are knowledgeable of the relevant policies.

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Ensure that all applicable fixed assets with a cost or value of $200 or over should be tagged, inventoried, and added to the fixed asset records according to CVLAS policy.

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Ensure a board member is involved in the review and approval process of the Executive Director's salary advance requests with documentation maintained on file.

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Ensure that staff understand the agreed upon terms and conditions of a specific salary advance and the agreement is documented.

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Ensure that the Audit and Finance Committee record financial decisions and approvals made by the governing body in accordance with LSC Accounting Guide, Section 3-5.2(b).

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Ensure budgets are built from cost centers or funding sources each year to identify details necessary for proper analysis and control of program spending.

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Ensure that written policies and procedures for cost allocation, credit cards, contracting, fixed assets, and payroll are included in the grantee's Accounting Manual, adequately describe the processes and controls in sufficient detail, and are in…

Date Issued

Revise the policies in CVLAS Accounting Manual to reflect new requirements included in 45 CFR Sections 1630 and 1631, effective December 31, 2017.