"Most A-133 audit findings relate to inadequate policies and procedures," according to Wayne Finley of the St. Petersburg, FL, mayor's office.
Finley was a featured speaker at the recent National Grants Management Association national conference here in the DC area. He listed the common audit findings, which included a host of items related to documentation:
- Failure to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA)
- Lack of competitive bidding documentation
- Progress reports not filed on time
- No separate set of expenditure ledger accounts to exclusively record grant program expenditures
- No personnel activity reporting system
- No signed time sheets
- No written approval for changes in key staff
- No documentation of fringe-benefit expense or rate
- No documentation or sole-source justification for consultant or equipment contracts
- No written contracts with consultants
- No documentation of expenditures for grant supplies
Lack of documentation is not just a deficiency for audits, where if you don't write it down it's as though you didn't do it. Lack of documentation means that even if you do everything right, it's not repeatable because you don't know exactly what you did last time. Documentation is what makes best practices repeatable. If you don't write it down, how can you be sure you will do it the right way again next time (or remember what you did wrong last time)? Documentation is a good thing whether or not you are being audited.