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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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All financial, performance and other required reports are submitted no later than 90 calendar days after the end date of the period of performance.

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Document justifications for all required reports submission extensions granted to the grantee. (repeat)

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Update the CNCS transaction code posting logic for recording grant expenditures to comply with the United States Standard General Ledger guidance. (repeat)

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Establish a requirement for Grant Officer/Portfolio Managers to provided documented certification that all required grantee information has been received, accepted, and documented before the grant is closed out. (repeat)

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Establish a control requiring the Grant Officer/Portfolio Manager to provide documented certification, upon grant closeout, verifying the total award amount to total award expenses for the deobligated recovery amount. (repeat)

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Inform all Grant Officers/Portfolio Managers to ensure that a reduction in funding to the award of a grant should be documented in eGrants which would result in modified Notice of Grant Awards. (new)

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Reconcile the amounts reported in Other Liabilities to supporting documents to verify that Other Liabilities are supported by valid transactions and properly classified. (repeat)

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Strengthen financial reporting internal controls and ensure that financial statements accounting line items are reviewed and reconciled to supporting documents prior to recording. The internal control activities should ensure proper posting of Member Payroll related liabilities on the Balance Sheet. (modified repeat)

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Enforce the agency-wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities. (repeat)

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Strengthen and refine the process for communicating CNCS facility-specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies. (repeat)

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Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems. (repeat)

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Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems. (repeat)

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Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. (repeat)

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Develop, implement and document procedures to identify all CNCS grantees that are required to submit single audit reports with their due dates. (new)

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Develop, implement and document procedures on timely follow-up for those grantees whose audits have become past due, and to ascertain why report submission was late, when the audit report will be submitted to the Federal Audit Clearinghouse, and what corrective action has been taken to prevent a report submission delay in future. (new)

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Develop a practice to capture the single audit data to assess the effectiveness of the single audit report submission for all its grantees. (new)

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Develop, implement and document procedures for implementing Office of Budget and Management (OMB) approved single audit report submission extensions, so that OMB approved extension approvals are documented and tracked as part of the single audit monitoring process. (new)

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Update the Single Audit Resolution Policy to: Reflect the current monitoring process to track all audit findings related to CNCS-funded grants, and   Address CNCS’s responsibilities as the cognizant/oversight agency and how these responsibilities would be carried out. (new)

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Develop and implement procedures to monitor the effectiveness of the single audit monitoring process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 Responsibilities, (a) (3) (iv), related to monitoring the effectiveness of single audit findings follow-up and the effectiveness of single audits in improving grantee accountability and in their use by CNCS in making award decisions. (new)