Audit of Selected Internal Controls at Coast to Coast Legal Aid of South Florida

Consult with LSC Management to develop processes, policies, and procedures to ensure CCLA’s engagement with LAS meets the criteria related to the existence of separate personnel per 45 CFR § 1610.8.

adequately document any changes or deviations to the administrative contract including, but not limited to, (1) addition and removal of administrative positions, and (2) changes to the agreed-upon allocation rate.

request, review, and verify adequate supporting document for the salaries and benefits paid to LAS, make necessary corrections or adjustments corresponding to the administrative contract in 2019. Document the review and results.

Reconsider other bases for billing for the administrative staff’s salaries and benefits instead of estimated or budgeted amounts with appropriate management and document on-file.

Update and document the formula for allocating CAM charges based on headcount when changes occur.

Review the terms of the lease agreement and update them accordingly to clearly define billing procedures for CAM charges including, but not limited to, the basis for the formula, review and approval process, and define what documentation should be…

ensure that the source documents for the CAM charges such as receipts, invoices and contracts are verified, documented, and maintained on-file.

Ensure that costs related to the administrative service contract and lease are allocated equitably among the applicable funding sources.

Update the Accounting Manual to ensure that the allocation methodology is (1) compliant with 45 CFR§ 1630.5(f) and (2) common expenses are allocated in fair, consistent, and in an equitable manner to individual cost centers, and funds.

Update the credit card policies to ensure that only authorized holders use them and to outline the role of the Executive Assistant with respect to credit card usage.

Ensure that CCLA staff follows the grantee’s policy that every employee reimbursement or purchase request be documented on the approved form. Also, keep documentations on-file.

Ensure that the Board's Executive Committee's review and approval of the Executive Director's credit card transactions is implemented, and documentation is kept on-file.

Ensure that LSC unallowable costs are charged to funding sources other than LSC and all CCLA staff is knowledgeable of LSC regulations and guidelines, in particular 1630.5(a).

Establish a written policy and procedure over the issuance and deactivation of credit card.

establish a credit card user agreement form for authorized users to sign and agree to proper use and repayment terms in case of unauthorized transactions.

Include policies and procedures for LSC unallowable costs in the Accounting Manual.

Ensure that LSC unallowable costs are charged to funding sources other than LSC and all CCLA staff is knowledgeable of LSC regulations and guidelines, in particular 1630.5(a).

ensure that CCLA staff follows its own policies as stated in the Accounting Manual and keep all documentation for submission and approval of requests on-file.

reassign the duties of receiving and opening the mail to staff who do not have access to or perform duties related to accounts payable.

reassign the duties of adding new vendors and updating vendor information to staff who do not have access to or perform duties related to accounts payable; and establish supervisory review and approval over adding and updating of vendor information.

Ensure that the property records include elements as required by the Fundamental Criteria.

ensure that a physical inventory is conducted every two years and results reconciled with the property records.

Establish clear and defined responsibilities over tagging IT equipment, furniture, and other inventory items.

Include tagging procedures of IT equipment, furniture, and other inventory items in the Accounting Manual, including but not limited to property purchased with LSC funds.

Ensure that no individual can initiate, execute, and record a payroll transfer without a second independent individual being involved in the process.

Ensure that outstanding checks for over three months are investigated and resolved.

Ensure that the bank reconciliations are performed monthly and timely.

Ensure that the person responsible for performing bank reconciliations documents the reconciliations with signature.

Ensure that the person responsible for reviewing and approving the bank reconciliations documents the review and approval with signature and date.

Review and restructure the user access rights over the payroll system so that employees who are system administrators are not able to change their own payrate.

periodically review the payroll register for verification of pay rates, including but not limited to changes to pay rates, and the addition or deletion of employees.

Ensure that staff receive training for completing, reviewing and approving electronic timesheets.

ensure that supervisors review and approve manual or electronic timesheets with signature and date.

Ensure that contracts along with all pertinent documents related to competition, evaluation of bids, sole source justifications, and rationale for vendor selections are maintained on-file.

establish a centralized filing system for all contracts and ensure documentation is maintained.

Develop written policies and procedures for budgeting that describe the processes and controls in sufficient detail in accordance with LSC’s Fundamental Criteria.

Include a specific deadline or prescribed number of days after month-end for the preparation of monthly management reports in the Accounting Manual.