Seattle, WA
United States
Audit on Selected Internal Controls at Northwest Justice Project
Report Information
Recommendations
Develop an allocation methodology that will ensure that all attorneys’ fees are proportionately allocated to the fund in which the LSC grant is recorded in the same proportion that the amount of LSC funds were spent on a case or representation.
Update and develop LSLRA written policies and procedures for (1) Non-Union Manager Level Staff and (2) the basis for determination of the attorney’s level of experience.
Review all LSLRA reimbursements within the audit period (January 1, 2022 to May 31, 2023) to verify that the employees reimbursed were at the experience level 24 and below, per the CBA. Document the results and any deviations from the policy, including…
Review the loan documentation submitted for LSLRA to ensure the documents included with the student loan statements contain the employees’ names, dates of the loan statements, and loan balances for the tuition reimbursements paid within the audit period…
Obtain the supporting documentation, containing the loan amount forgiven and loan forgiveness date, from the student loan servicer for the employee with the student loan forgiven in 2023.
We recommend that the Executive Director update the written policies and procedures for LSLRA to include the following:• Specific, required loan documentation. For example, monthly loan statements from the student’s loan servicer, complete with name,…
We recommend that the Executive Director notify and obtain approval from LSC for the purchase of 50 laptops exceeding $25,000.
We recommend that the Executive Director develop and implement a process for tagging capitalized property and equipment.
We recommend that the Executive Director conduct a physical inventory of capitalized property and equipment as soon as possible, document the results, and do so at least every two years.
Update and implement contracting policies to include the following: • requirements for sole source justification;• discouragement of automatically renewing contracts, when possible and if terms allow. If automatically renewing contracts are…
We recommend that the Executive Director implement a control to ensure only authorized cardholders have access to card information. In the event another staff member needs to use a credit card and the cardholder cannot make the purchase for them,…
We recommend that the Executive Director ensure credit card user acknowledgment agreements are signed by all cardholders.
We recommend the Executive Director update NJP’s written policies for credit cards to include, at a minimum, the following:• guidelines on personal use and disallowed charges;• guidelines on properly documenting any deviations from policy;• restrictions…
We recommend that the Executive Director document the complete cost allocation process including the adjustments made to arrive at the final allocations for indirect costs.
We recommend that the Executive Director enable distinct user access roles for the NJP accounting staff that are commensurate with their responsibilities to ensure adequate segregation of duties is maintained in the accounting software.
We recommend that the Executive Director implement a process requiring dated approvals prior to expenses being incurred.
We recommend the Executive Director establish a process to document advance approval for employee travel, and, if appropriate, set a threshold above which such approval must be documented and not only given verbally.
We recommend that the Executive Director develop policies to ensure the timely disposition of outstanding checks.
We recommend that the Executive Director ensure NJP’s Accounting Manual (and, if applicable, Personnel Manual) is updated to include the grantee’s processes surrounding the referenced criteria. This includes:• payroll procedure details,• roles/…