SOUTHWEST INDIGENOUS WOMENS COALITION

2023-001 Late Single Audit Submission (Significant Deficiency) Criteria or Specific Requirements: Section 200.512(a)(1) Report Submission of the Office of Management and Budget’s Uniform Guidance outlines the following requirement: “The audit must be completed, and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period, whichever is earlier.” Condition: SWIWC did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of September 30, 2024). Cause: SWIWC did not maintain audit documentation in a manner that allowed timely completion of the audit. Effect: Noncompliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high-risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

2023-002 Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Material Weakness) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds 21.027 418-22 Criteria or Specific Requirement: To help ensure that expenditures charged to the programs are allowed:  By the grant agreements and to comply with 2 Code of Federal Regulations (CFR) Part 200, Subpart E – Cost Principles, SWIWC should maintain all supporting documentation, including reviewed and approved invoices.  All costs should support the objectives of the grant. Condition: During our testing of program expenditures, we noted that adequate supporting documentation was not provided for 14 of the 40 transactions selected for testing. Questioned Costs: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) - $70,587. Cause: SWIWC did not provide adequate documents. Effect: There is an increased risk of payments being made for goods or services not received and of unallowable charges to the federal programs or with complying with federal program requirements for claiming administrative costs. Auditor's Recommendations: To help ensure that expenditures are allowable and to help maintain an effective internal control environment over expenditures, SWIWC should follow the existing policies and procedures for obtaining, reviewing and approving expenditure transactions. In addition, SWIWC should ensure that all supporting documentation is properly maintained and that expenditures are based on actual costs.

2023-003 Procurement, Suspension, and Debarment - (Material Weakness) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds 21.027 418-22 Criteria or Specific Requirement: In accordance with 2 CFR Section 200.214 of the Uniform Guidance states that SWIWC must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: During our testwork over procurement, for ten samples tested, SWIWC was unable to provide adequate supporting documentation demonstrating that required procurement procedures were performed in accordance with established policies and applicable Uniform Guidance requirements. Cause: SWIWC did not consistently follow or maintain adequate documentation of its established procurement policies and procedures. Effect: SWIWC did not demonstrate compliance with applicable procurement requirements under the Uniform Guidance. As a result, there is an increased risk that purchases may not be properly authorized, adequately supported, competitively procured, or otherwise compliant with federal requirements. Auditor's Recommendations: We recommend that SWIWC strengthen its procurement monitoring controls to ensure personnel consistently follow established procurement policies and procedures. SWIWC should also require complete documentation for each procurement transaction, including approvals, quotations or bids, vendor selection support, and other applicable procurement records.