Young Mens Christian Association of Boulder Valley

Criteria or Specific Requirement – Management is required to ensure that there are sufficient internal controls in place over payroll costs charged to the program. This includes internal controls that ensure that all supporting documentation is retained to demonstrate compliance. Conditions – Documentation supporting employee costs charged to the program was unavailable or incomplete for some selections. Context – During our testing of allowable costs and activities, we selected two employees for payroll testing. For each employee selected, we were able to verify the validity of the employee. However, we were not able to validate the approved rate of pay. Cause – For periods for which payroll records were not available, the Organization was using a different payroll process system. As a result, such records could no longer be accessed. Effect – Complete documentation to support certain payroll transactions was not available. We were able to verify the existence of the employee. We were also able to verify that the amounts charged were reasonable based on the nature of the program as well as subsequent activity. As a result, we considered the total costs charged to the program to be reasonable. However, internal controls were not in place related to the proper retention of records. Views of Responsible Officials and Planned Corrective Actions — Management agrees with the finding and in the future will take steps to retain or insure that access to records continues to be available.

Criteria or Specific Requirement – Per 2 CFR §180.300 and §200.214, non-federal entities are prohibited from entering into covered transactions (e.g., contracts or subawards expected to equal or exceed $25,000) with parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Conditions – Verification of SAMS.gov vendors was not performed. Context – During our testing of procurement, we sampled nine expenditures totaling $367,163. The total population of procurement expenditures charged to the program was $800,000. We noted that all nine selections of expenditures did not have SAMS.gov verification documentation. Cause – The Association did not have a formal process or checklist to ensure that vendors were checked against the SAM.gov exclusion list before contract award. Procurement staff were not trained on this requirement. Effect – Use of non-approved vendors could have occurred. However, as part our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website. Recommendation – We recommend the Association implement a formal policy and procedure to verify all vendors against SAM.gov for covered transactions exceeding $25,000. Staff responsible for federal procurement should be trained, and documentation of vendor status verification should be retained with procurement records. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.

Criteria or Specific Requirement – Under 2 CFR §200.320(a), micro-purchase procedures may be used for procurements up to the micro-purchase threshold (currently $10,000). Purchases must be distributed equitably among qualified suppliers when practical, and the price must be reasonable. Entities must follow their internal controls and maintain documentation supporting the rationale for the purchase and vendor selection. Conditions – Bids for some vendors was not performed. Context – During our testing of procurement, we sampled nine expenditures. Of the nine selections three selections did not have required bids. Cause – The Association lacks formal procedures to ensure micro-purchase requirements are met, and staff were not aware of the requirement to document price reasonableness or distribute purchases equitably among vendors. Effect – Higher than necessary costs may be have expensed.Recommendation – We recommend that management revise policies to ensure proper vendor compliance in the future. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.

Criteria or Specific Requirement – Recipients of federal awards are required to submit accurate, complete, and timely financial and performance reports as specified in the terms and conditions of the award. Conditions – Required program reporting was not followed. Context – During our testing of reporting, we noted two required semi-annual progression reports were not completed for the June 2023 through June 2024 period. Additionally, approval for budget change was not obtained prior to submission of expense reports for reimbursement. Cause – The delays resulted from a lack of internal tracking mechanisms for report deadlines. Effect – Noncompliance with federal reporting requirements may hinder federal oversight, delay reimbursements, and expose the Association potential enforcement actions or funding restrictions.. Recommendation – We recommend that management ensure that all grant reporting is tracked to ensure future compliance. Views of Responsible Officials and Planned Corrective Actions – Reporting requirements will be tracked to support requirements in the future.

Criteria or Specific Requirement – Management is required to ensure that there are sufficient internal controls in place over payroll costs charged to the program. This includes internal controls that ensure that all supporting documentation is retained to demonstrate compliance. Conditions – Documentation supporting employee costs charged to the both major programs was unavailable or incomplete. Context – During our testing of allowable costs and activities for the Child Care and Development Block Grant, we selected twenty-seven journal entries for payroll testing. The Organization provided us detail listings for each of the twenty-seven journal entries which included employees and charges that supported the journal entry and we were able to make sub selections to the employee level. For each employee selected, we were able to verify the validity of the employee. However, we were not able to validate the approved rate of pay. During our testing of allowable costs and activities, for the SLFRF grants we selected two journal entries for payroll testing. The Organization provided us detail listings for each of the two journal entries which included employees and charges that supported the journal entry and we were able to make sub selections to the employee level. For each employee selected, we were able to verify the validity of the employee. However, for one of the selections which was charged to the SLFRF pass-through grant from Laramie County, WY, we were not able to validate the approved rate of pay. Cause – For periods for which payroll records were not available, the Organization was using a different payroll process system. As a result, such records could no longer be accessed. Effect – Complete documentation to support certain payroll transactions was not available. We were able to verify the existence of the employee. We were also able to verify that the amounts charged were reasonable based on the nature of the program as well as subsequent activity. As a result, we considered the total costs charged to the program to be reasonable. However, internal controls were not in place related to the proper retention of records.

Criteria or Specific Requirement – Management is required to ensure that there are sufficient internal controls in place over expenses charged to the program. This includes internal controls that ensure that expenditures are verifiable with adequate supporting documentation. Conditions – Documentation for certain expenditures was not maintained to support the expenditures charged to the Child Care and Development Block Grant program. Context – During our testing of allowable costs and activities, we sampled thirteen non-payroll expenditures totaling $20,257. The total population of non-payroll expenditures charged to the program was $422,829. In our sample, we found that two selections of expenditures totaling $1,373 did not have adequate supporting documentation on file. In the same sample, we also identified one expenditure totaling $2,345 which may be unallowable and is reported as a separate finding (see finding 2023-003). Cause – Supporting documentation was not consistently maintained. Effect – Unallowable costs may have been charged to the program.

Criteria or Specific Requirement – Management is required to ensure that costs charged to the program are allowable costs. This includes having internal controls that ensure that all costs are allowable costs. Conditions – Unallowable costs may have been charged to the Child Care and Development Block Grant program. Context – During our testing of allowable costs and activities, we noted that the Organization charged mileage expenses to the program, which may be unallowable. Sampled costs related to mileage was $2,345. Through further audit procedures we determined that total mileage costs charged to the program, which may be unallowable, was $12,907. Cause – Existing procedures surrounding the determination of allowable costs of non-payroll costs were not followed. Effect – Mileage was charged to the program which may be unallowable costs.

Criteria or Specific Requirement – A portion of the SLFRF ARPA Scholarship program was to provide funding for CCAP losses incurred for Boulder County Children. Management is required to ensure that there are sufficient internal controls in place over expenses charged to the SLFRF program. This includes internal controls that ensure that reports used in determining expenditures are complete, accurate, and compliant with the program. Conditions – Documentation used for calculating expenditures was not accurate. Context – During our testing of allowable costs and activities, we reviewed reports used for CCCAP loss calculations. We selected six of nineteen locations to verify the Boulder County resident percentage used for allowable expenditures. The six locations accounted for 82% of all students. We noted the number of students did not agree between the reports used for the calculations and the support provided. However, the errors resulted n more expenses being allowable; as a result, there are no questionable costs. Cause – Controls were not in place to ensure correct data was gathered to provide for accurate reporting. Effect – Reports submitted were inaccurate.

Criteria or Specific Requirement – A portion of the funds received under the SLFRF ARPA Scholarship Program was to provide financial aid to children of Boulder County residents who are low-income and/or historically marginalized who have disparate access to childcare services. Conditions – Unallowable costs may have been charged to the program. Context – In our testing of financial assistance provided, we selected 25 recipients who in total received $11,384 in financial aid. The grant was for a total of $500,000 of which $350,000 was for financial aid. In our sample, we found the following instances in which the recipients of financial aid may not have been eligible: • 3 of the recipients of financial aid were children of employees of the Organization. Financial aid of $3,333 was provided to these recipients without verification of eligibility. • For 7 of our selections totaling $2,216, documentation was not on file to support eligibility. Cause – Established controls for determining allowable activity were not adequate. Effect – Employee childcare was charged to the program which may be unallowable costs.

Criteria or Specific Requirement – The Organization had reporting requirements for the SLFRF grants. Conditions – Required program reporting was not followed. Context – During our testing of reporting, we sampled four required reports. In our sample, we found that for one selection, Boulder County ARPA Capital Project, required reporting was not completed for the October through November 2023 period. Cause – Controls to ensure proper reporting were not sufficient. Effect – Required reporting requirements were not met.

Criteria or Specific Requirement – Management is required to ensure that there are sufficient internal controls in place over SLFRF program purchasing. This includes internal controls that ensure that approved vendors are used for purchases in excess of $25,000. Conditions – Verification of SAMS.gov vendors was not performed. Context – During our testing of procurement, we sampled three expenditures totaling $595,584. The total population of procurement expenditures charged to the program was $725,854. We noted that all three selections of expenditures did not have SAMS.gov verification documentation. Cause – Procurement policy was not sufficient to ensure full compliance. Effect – Use of non-approved vendors could have occurred. However, as part our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website.