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Audit of the Corporation for National and Community Service’s (CNCS) Fiscal Year 2019 Consolidated Financial Statements

Date Issued
Report Number
20-01
Report Type
Audit
Description
For the third year in a row, an independent audit of CNCS’s consolidated Fiscal Year 2019 financial statements resulted in a disclaimer of opinion, the worst possible outcome for a financial statement audit. CNCS cured none of the ten material weaknesses and two significant deficiencies from the prior year audit. Three of the material weaknesses and one significant deficiency were first identified in the FY 2017 audit. In short, CNCS’s financial statements were unauditable and CNCS was unable to support some of its largest transactions and liabilities. The financial statements published by CNCS likely contain widespread material errors and should not be relied upon. Key audit findings were: • Disclaimer of Opinion: CNCS was unable to provide adequate evidential matter to support a significant number of transactions and account balances due to inadequate processes and controls to support transactions and estimates and incomplete records to support accounting for transactions in accordance with the generally accepted accounting principles. The independent auditors were unable to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. In addition, CNCS did not provide the documentation necessary for the auditors to assess the accuracy and completeness of certain year-end balances. • Material weaknesses and significant deficiencies in CNCS’s internal control over financial reporting included: Material Weaknesses: Internal Controls Program: The system of internal controls failed to identify numerous and pervasive material weaknesses that the auditors found in financial reporting and in specific material line items on the financial statements; Financial System and Reporting: CNCS’s financial reporting was hindered by limitations in its financial system and the timing and difficulties arising from insufficient accounting staff and inadequate internal controls; Trust Obligations and Liability Model: There were inconsistencies between the assumptions used and how those assumptions were applied in the estimation of the Trust obligations and liabilities. The revised Trust model used to establish the liability included calculation errors and lacked quality controls, which impair significantly the accuracy of the reported liability; Grants Accrual Payable and Advances: CNCS excluded estimated “incurred but not reported” costs from the accrued expenses and liability for at least $23.3 million as of June 30, 2019. It has not validated the method used to calculate the estimate as reasonable; Undelivered Orders and Accounts Payable – Procurement: There were flaws in CNCS’s accounts payable accrual methodology. It also did not have adequate internal controls to ensure the accuracy of obligated balances or to de-obligate stale and invalid obligations related to contracts and purchase orders; Property and Equipment: CNCS did not timely capitalize and failed to support its Software-in-Development and tenant improvement amortization costs, including a write-off of $33.8 million dollars for an unsuccessful software development project; Undelivered Orders – Grants: Auditors found significant unexplained disparities between CNCS’s accounting records and its grant records regarding grant expenditures and grant award amounts; Recoveries of Prior Year Obligations: CNCS was unable to provide any documentation to support more than half of the sampled transactions; and Other Liabilities: CNCS was unable to provide any supporting documentation for approximately $2.4 million reported as of June 30, 2019. o Significant Deficiencies: Information Technology Security Controls: Auditors found new and recurring weaknesses in the information security program with respect to configuration management, access control and security management; and Accounts Receivable and Allowance for Doubtful Accounts: CNCS did not follow its Debt Management Policy by writing off Accounts Receivable items delinquent for two years or more. An instance of noncompliance with provisions of laws and regulations with respect to Single Audits, which could have a direct and material effect on financial statement accounts and disclosures. CNCS did not adequately monitor the effectiveness of nor fully develop performance metrics to track the CNCS single audit monitoring process. The audit report made 75 recommendations to CNCS, including immediate corrective actions to address pervasive material weaknesses and significant deficiencies. CNCS’s response asserts that it has “invested significant time and effort . . . responding to previous audit recommendations” and “continues to demonstrate its commitment to improving financial management reporting and operations.” Though stating that CNCS “partially concurs with the conditions and recommendations in the report,” CNCS did not respond to specific findings. The sole exception concerns the National Service Trust, where CNCS’s response reflects a misunderstanding of the auditors’ concern, which CNCS-OIG will remedy. Finally, CNCS notes that it will be migrating to shared services for accounting at the beginning of FY 2021 and “will incorporate [the auditors’] recommendations where appropriate.” The independent accounting firm of CliftonLarsonAllen LLP, performed the audit of the CNCS FY 2019 consolidated financial statements, under contract with CNCS-OIG.
Joint Report
No
Agency Wide
Yes
Questioned Costs
$0
Funds for Better Use
$0

Open Recommendations

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Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

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Tracking the sequence of SVs/JVs for completeness;

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Appropriate use of SVs/JVs;

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Determining and maintaining relevant documentation to support each SV/JV;

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Use of specific and accurate SV/JV descriptions; and

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Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

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Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds applied; update accounting transactions, and clearly identify periods when adjustments will be made regardless of materiality. (new)

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Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service provider to determine methods that would enhance the security and quality of the existing estimation models. (new)

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Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

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Conduct detailed analysis and validation of data sources.

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Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

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Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary.

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Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

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Document and implement policies and procedures to include the following:

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Establish a thorough and robust quality control process to ensure that the Trust Obligation and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by qualified CNCS personnel prior to relying on its outputs to record transactions. All errors identified for which management ultimately decided against making updates to the TOLM or Calculator should be documented along with an explanation as to how management arrived at the final decision;

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Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

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Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

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Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

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Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

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Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

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Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of key controls. (modified repeat)

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Develop a succession plan to ensure the required expertise is available in anticipation of planned employee turnover, particularly with respect to the complex trust calculations. CNCS needs to:

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Train, mentor, and work to retain qualified employees;

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Cross-train employees so that knowledge of the model will reside with multiple staff rather than with one person; and

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Implement a peer review process to carry out the necessary quality control reviews of the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

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Coordinate with the program and grant officers to gather and analyze key grant programs’ (AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending pattern to develop the following key factors for grant accrual estimation:

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Percentage of CNCS grantees who drawdown funds in advance versus those on a reimbursable basis and their related grant amounts to its grant spending as a whole. If different key programs have different spending patterns, perform this analysis at the program level;

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An inventory of relevant and reliable grant data to be used for the grant accrual assumptions and documentation to support what data is considered relevant and reliable;

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Grantees' incurred but not reported (IBNR) reporting pattern from when the expenses have been incurred to the time those expenses are included the grantees' Federal Financial Reports (FFR). Grantee surveys may be conducted to confirm the reasonableness of an IBNR estimate methodology. When alternative procedures are used, management should provide its data-based analysis to validate its assertion; and

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Post-accrual analysis to compare the accrual (without the IBNR) and the expenditures reported in the FFRs for the same quarter. Thresholds should be established and documented based on materiality and the degree of risk that management is willing to accept. When grantees' reported spending pattern deviates from its methodology, an analysis should be performed to determine whether any deviation is acceptable or the methodology should be further refined to reflect the actual grantees' reported expenditure pattern. (modified repeat)

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Revise and implement policies and procedures for the grant accrual methodology so that:

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A validation process is established for management to verify the accuracy of the grant accrual, so that management can make any necessary adjustments to improve the precision of the grant accrual and to account for grant advances and payables to ensure the resulting amounts are materially consistent with grantees’ drawdown and spending patterns;

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It addresses how the calculations are used to arrive at the Grants Payable and Advances to Other line items in the financial statements. (modified repeat)

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Develop a process to validate grant advances, incurred but not reported and payable estimates. Such validation should be performed for all program elements included in the estimation process and over a few years to show a trend of the estimates. Unusual fluctuations, if any, should be investigated and the research conclusions documented. (modified repeat)

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Strengthen internal control to ensure procurement documents are properly approved and retained. (repeat)

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Analyze procurement undelivered orders balances quarterly to verify that balances are still valid for those without financial activities for an extended period. (repeat)

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Research, resolve and document the disposition of any abnormal undelivered orders transactions/balances. (repeat)

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Conduct validation assessment of amounts accrued for the incurred but not reported on a periodic basis. As part of the validation, CNCS should consider the following:

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Subsequent activities against the amount estimated to determine the level of precision in the estimation;

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Trend the validation results and adjust the incurred but not reported estimation process to address any recurring significant fluctuations; and

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Update the incurred but not reported estimation process as necessary to reflect changes in payment patterns. (repeat)

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Evaluate the materiality thresholds used in the accrual estimation to ensure it is appropriate to prevent misstatements. The materiality threshold used should be appropriate that, in the aggregate, identified misstatements would not rise to a level that will significantly impact management’s assertions on the financial statements. (new)

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Implement controls to ensure that transactions interfaced from eGrants are reflected in Momentum for the correct amounts, accounts, and number of transactions. (new)

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Update CNCS policy to recognize and record capitalized costs in the period incurred. (repeat)

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Update CNCS policy to include requirements for compliance with accounting standards; track direct labor and other indirect costs, including hours, worked and payroll costs dedicated to existing and new software-in-development projects; track and amortize tenant improvement costs in accordance with the lease agreement. (new)

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Consult with the future shared service provider and other stakeholders to determine the feasibility of procuring and using project management software to track project costs from the inception to completion. The results of the analysis should be documented and made readily available. (new)

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Determine the root cause behind the differences noted in the Undelivered Orders balance between Momentum and the Undelivered Orders balance derived from the net of grant award amount from the Notice of Grant Award and the grant expenditures from the Payment Management System, and take the appropriate steps in resolving the reason behind the variances that are occurring. (new)

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Determine the root causes and resolve discrepancies in the grant award amounts recorded in the NGA in eGrants and in Momentum to prevent such differences from occurring in the future. (repeat)

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Determine the root causes and resolve expenditure differences between the Payment Management System and Momentum. (repeat)

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Strengthen controls around the review of expired grant obligations by ensuring that: