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GAO-11-825R: 

United States Government Accountability Office: 
Washington, DC 20548: 

September 9, 2011: 

Mrs. Erica Heyse: 
National Director: 
Congressional Award Foundation: 

Subject: Management Report: Opportunities for Improvements in the 
Congressional Award Foundation's Internal Controls and Accounting 
Procedures: 

Dear Mrs. Heyse: 

In May 2011, we issued our opinion on the fiscal years 2010 and 2009 
financial statements of the Congressional Award Foundation (the 
Foundation).[Footnote 1] We also reported on our evaluation of the 
Foundation's compliance with provisions of selected laws and 
regulations for the fiscal year ended September 30, 2010, and our 
consideration of the Foundation's internal control over financial 
reporting. 

The Foundation was formed in 1979 under the Congressional Award Act 
and is a private, not-for-profit, tax-exempt organization under 
section 501(c)(3) of the Internal Revenue Code. It was established to 
promote initiative, achievement, and excellence among young people in 
the areas of public service, personal development, physical fitness, 
and expedition. During fiscal year 2010, there were approximately 
28,700 participants registered in the Foundation's award program. 
Although the organization does not receive federal funding, we are 
responsible for conducting audits of the Foundation's financial 
statements annually in accordance with section 107 of the 
Congressional Award Act, as amended (2 U.S.C. § 807). 

In our previous year's audit of the Foundation's fiscal years 2009 and 
2008 financial statements,[Footnote 2] we reported a material weakness 
[Footnote 3] in the Foundation's internal control over financial 
reporting. This resulted in the need for material adjustments in 
finalizing the Foundation's fiscal year 2009 financial statements to 
achieve a fair presentation. In a September 9, 2010, report to the 
Foundation,[Footnote 4] we provided further details on the control 
deficiencies that constituted this material weakness, as well as 
recommendations for corrective action. In response to our 
recommendations, during fiscal year 2010, the Foundation took a number 
of actions to address the material weakness. However, certain control 
deficiencies over the Foundation's financial reporting process 
remained in fiscal year 2010 and, while no longer constituting a 
material weakness, represented a significant deficiency in internal 
control that continued to place the Foundation at increased risk of 
errors or omissions in its financial statements.[Footnote 5] Further 
actions, as presented in our September 9, 2010, report, are needed to 
address these remaining control deficiencies. 

During our audit of the Foundation's fiscal years 2010 and 2009 
financial statements, we identified additional deficiencies in the 
Foundation's internal control that we do not consider to be material 
weaknesses or significant deficiencies, either individually or in the 
aggregate, but that nonetheless merit Foundation management's 
attention and correction. The purpose of this report is to present 
additional information on the internal control and accounting 
procedures issues we identified during our audit of the Foundation's 
fiscal years 2010 and 2009 financial statements and to provide our 
recommended actions to address those issues. We are making four 
recommendations for strengthening the Foundation's internal controls 
and accounting procedures. In addition, we are providing an update on 
the status of recommendations we made to address internal control 
issues identified during our audit of the Foundation's fiscal year 
2009 financial statements as reported in our September 9, 2010, 
management report on internal controls and accounting procedures. 

Results in Brief: 

During our audit of the Foundation's fiscal years 2010 and 2009 
financial statements, we identified three internal control issues that 
could adversely affect the Foundation's ability to meet its internal 
control objectives. These issues concern the Foundation's lack of 
documented policies and procedures for: 

* year-end accrual of expenses, 

* reconciliations and supervisory reviews of schedules supporting 
certain transactions to ensure that these transactions are recorded 
appropriately, and: 

* recording of silent auction revenue. 

These issues increase the risk of the Foundation not preventing or 
timely detecting and correcting errors in its financial reporting. 

At the end of our discussion of each of these issues in the sections 
that follow, we present our recommendations for strengthening the 
Foundation's internal controls and accounting procedures. These 
recommendations are intended to improve management's oversight and 
controls and minimize the risk of misstatements in the Foundation's 
accounts and financial statements. 

As of the completion of our fiscal year 2010 audit on May 6, 2011, the 
Foundation had taken action to fully address 11 of the 16 
recommendations related to internal control and accounting procedures 
from our fiscal year 2009 audit. The Foundation also took action to 
address the remaining 5 internal control and accounting procedures- 
related recommendations, but more work is needed to fully resolve the 
underlying control issues. 

In its comments, the Foundation agreed with our recommendations and 
described actions it is taking to address the control issues described 
in this report. At the end of our discussion of each issue in this 
report, we have summarized the Foundation's related comments and 
provided our evaluation. We have reprinted the Foundation's comments 
in enclosure II. 

Scope and Methodology: 

This report addresses issues we identified during our audit of the 
Foundation's fiscal years 2010 and 2009 financial statements. In 
planning and performing our audit of the Foundation's fiscal years 
2010 and 2009 financial statements, we considered the Foundation's 
internal control over financial reporting for the purpose of 
determining our procedures for auditing the financial statements, not 
to express an opinion on the effectiveness of internal control. 
Accordingly, we did not express an opinion on the Foundation's 
internal control over financial reporting. 

While our full scope and methodology used in carrying out our fiscal 
years 2010 and 2009 audit is detailed in our May 2011 report, in 
summary, to fulfill our responsibilities as auditor of the financial 
statements of the Foundation, we examined, on a test basis, evidence 
supporting the amounts and disclosures in the financial statements; 
assessed the accounting principles used and significant estimates made 
by Foundation management; evaluated the overall presentation of the 
financial statements and notes; obtained an understanding of the 
Foundation and its operations, including its internal control over 
financial reporting; assessed the risk that a material misstatement 
exists in the financial statements; tested relevant internal controls 
for the purposes of planning and performing our other audit 
procedures; tested compliance with selected provisions of the 
Congressional Award Act, as amended; and performed such other 
procedures as we considered necessary in the circumstances. We 
conducted our audit of the Foundation's fiscal years 2010 and 2009 
financial statements in accordance with U.S. generally accepted 
government auditing standards. We believe that our audit provided a 
reasonable basis for our conclusions in this report. 

Year-end Expense Accruals: 

During our fiscal year 2010 audit, we found that the Foundation's 
internal controls were not always effective in ensuring that the 
Foundation properly accrued liabilities for expenses at the end of the 
fiscal year.[Footnote 6] For example, during our testing of accrued 
expenses, we found that the Foundation recorded an expense for office 
supplies of over $1,000 in fiscal year 2010, of which only about $400 
related to fiscal year 2010. 

We also found that the Foundation accrued a liability for three 
expenses totaling over $500 as of September 30, 2010, yet the goods 
and services were not received or provided until fiscal year 2011, and 
therefore the liability should not have been incurred until then. We 
determined that the Foundation was incorrectly accruing expenses for 
goods and services ordered by fiscal year-end, rather than for goods 
and services received or provided by that date. 

These errors occurred because the Foundation did not have documented 
policies and procedures regarding the year-end accrual of expenses. 
Specifically, the Foundation's current accounting policies and 
procedures did not address the process and criteria for accruing 
expenses. 

The Standards for Internal Control in the Federal Government[Footnote 
7] provides that management develop the detailed policies, procedures, 
and practices to fit an organization's operations. The standards also 
provide that transactions and other events be accurately and timely 
recorded to maintain their relevance and value to management in 
controlling operations and making decisions. This includes determining 
the appropriate fiscal year in which liabilities and expenses are 
recognized under U.S. generally accepted accounting principles. 

Without documented policies and procedures to address the accrual of 
expenses at the end of the fiscal year, the Foundation increases the 
risk that liabilities and expenses may not be recorded in the proper 
accounting period. 

Recommendation: 

We recommend that the Foundation modify its documented accounting 
policies and procedures to address the year-end accrual of expenses. 
Such modifications should stipulate that expenses be recognized and a 
liability incurred when goods or services have been received. 

Foundation Comments and Our Evaluation: 

The Foundation agreed with our recommendation and stated that it is 
drafting accounting policies and procedures to ensure that expenses 
are recognized when the goods or services have been received; upon 
completion, the new policies and procedures will be approved by the 
Board of Directors. We will evaluate the effectiveness of the 
Foundation's corrective actions during our fiscal year 2011 financial 
audit. 

Reconciliation and Supervisory Review Process: 

During our fiscal year 2010 audit, we found that the Foundation lacked 
effective controls to ensure that schedules supporting the recording 
of certain types of transactions in its general ledger were accurate 
and reconciled to the general ledger. This led to a number of errors 
in recording transactions that the Foundation's management did not 
detect. For example: 

* During our testing of prepaid expenses,[Footnote 8] we found that 
the Foundation's prepaid insurance amortization schedule did not 
reconcile to the general ledger, resulting in undetected errors in the 
recording of prepaid expenses. For example, the Foundation purchased 
worker's compensation insurance that covered the period from February 
2010 through February 2011, but did not record the first month's 
prepaid expense amortization[Footnote 9] of almost $100 in the general 
ledger. We also found that although the Foundation correctly excluded 
an insurance audit adjustment of over $200 from the prepaid insurance 
amortization schedule, the prepaid expense balance in the general 
ledger on September 30, 2010, included this amount because the 
Foundation recorded it as a prepaid expense in April 2010, when it 
should have been expensed during fiscal year 2010. 

* During our testing of depreciation expense,[Footnote 10] we found 
that the Foundation's depreciation and amortization schedule did not 
reconcile to the general ledger, resulting in an undetected error in 
the recording of depreciation expense. Specifically, in December 2009, 
in addition to the standard monthly depreciation entry for furniture 
and equipment, the Foundation erroneously recorded a second entry in 
the general ledger that resulted in monthly depreciation expense being 
overstated by over $300. 

* During our testing of amortization expense, we found that the 
Foundation incorrectly calculated capital lease amortization on its 
depreciation and amortization schedule, which is used to record 
amortization expense in the general ledger. The Foundation erroneously 
discontinued amortization of one of its capital leases for 4 months. 
As a result of this error on the depreciation and amortization 
schedule, amortization expense in the general ledger was understated 
by almost $100. 

* During our testing of the costs of direct benefits to donors, 
[Footnote 11] we found several errors in the data used to calculate 
this amount. The costs of direct benefits to donors amount for each 
special event is calculated by multiplying the number of participants 
attending the event for each donor by the cost per participant for the 
event. These amounts for each event are then added together to arrive 
at the total costs of direct benefits to donors amount reported on the 
financial statements. The Foundation prepared schedules to record the 
data used for this calculation, but we found that these schedules 
included an incorrect number of participants attending a special event 
for two event donors, resulting in a net understatement of over $500 
to costs of direct benefits to donors reflected in the initial draft 
of the Foundation's financial statements. 

The errors that occurred were not detected because the Foundation did 
not have documented policies and procedures in fiscal year 2010 
requiring that the prepaid insurance amortization, depreciation and 
amortization, and costs of direct benefits to donors schedules 
supporting amounts in the general ledger be routinely reconciled to 
the general ledger and be reviewed by supervisors. In December 2010, 
the Foundation completed a review of its accounting policies and 
procedures and made significant revisions, including requiring that 
the depreciation and amortization and costs of direct benefits to 
donors schedules be reconciled to the general ledger. While these new 
requirements should address some of the issues we identified, the 
updated accounting policies and procedures did not require these 
schedules to be reviewed by supervisors, nor do they address the need 
for routine reconciliation and supervisory review of the prepaid 
insurance amortization schedule. 

The Standards for Internal Control in the Federal Government provides 
that internal control should generally be designed to ensure that 
ongoing monitoring occurs in the course of normal operations, 
including regular management and supervisory activities, comparisons, 
and reconciliations. Without reconciliations and effective supervisory 
reviews to help ensure that transactions are accurately recorded and 
independently reviewed, the Foundation increases its risk that amounts 
may not be properly recorded in its financial statements. 

Recommendations: 

We recommend that the Foundation: 

* modify its documented accounting policies and procedures to require 
routine reconciliation and supervisory review of the prepaid insurance 
amortization schedule supporting transactional activity to be recorded 
in the general ledger to ensure that transactions are recorded 
appropriately and: 

* modify its documented accounting policies and procedures to require 
that supervisory review of the depreciation and amortization and costs 
of direct benefits to donors schedules supporting transactional 
activity be recorded in the general ledger to ensure that transactions 
are recorded appropriately. 

Foundation Comments and Our Evaluation: 

The Foundation agreed with our recommendations and stated that it is 
drafting accounting policies and procedures to ensure that routine 
reconciliations and supervisory review of the prepaid insurance 
amortization, the depreciation and amortization of assets, and costs 
of direct benefits to donors is performed on a routine basis; upon 
completion, the new policies and procedures will be approved by the 
Board of Directors. We will evaluate the effectiveness of the 
Foundation's corrective actions during our fiscal year 2011 financial 
audit. 

Recording Silent Auction Revenue: 

During our fiscal year 2010 audit, we found that the Foundation's 
internal controls were not fully effective in ensuring the accurate 
recording of certain types of revenue. Specifically, we found that the 
Foundation erroneously recorded revenue in its general ledger for 
silent auction items[Footnote 12] sold at one of its fund-raising 
events. The Foundation first recorded the revenue as an in-kind 
contribution[Footnote 13] when the items were donated. When the silent 
auction was held and donors purchased the auction items, the amount 
received was recorded again as program and other revenue. However, 
rather than recording the entire amount received from the auction, the 
Foundation should have only recorded the difference between this 
amount and the amount initially recorded when the items were donated 
as an adjustment to the original contribution. This error resulted in 
revenue being overstated by over $9,000. The error occurred because 
the Foundation's existing accounting policies and procedures lacked 
guidance for recording silent auction revenue. 

The Standards for Internal Control in the Federal Government provides 
that management develop the detailed policies, procedures, and 
practices to fit the organization's operations. Without documented 
policies and procedures for recording silent auction revenue, the 
Foundation increases its risk that revenue may be misstated. 

Recommendation: 

We recommend that the Foundation modify its existing accounting 
policies and procedures to include guidance and requirements for the 
recording of silent auction revenue. The modified policies and 
procedures should require that the revenue be recorded at fair value 
when items are donated and subsequently adjusted to the amount 
received when the silent auction is held and donors have purchased the 
items. 

Foundation Comments and Our Evaluation: 

The Foundation agreed with our recommendation and stated that it is 
drafting changes to its accounting policies and procedures related to 
this issue; upon completion, the new policies and procedures will be 
approved by the Board of Directors. We will evaluate the effectiveness 
of the Foundation's corrective actions during our fiscal year 2011 
financial audit. 

Status of Fiscal Year 2009 Audit Recommendations: 

During our audit of the Foundation's fiscal year 2009 financial 
statements, we identified seven internal control issues and made 16 
recommendations for corrective actions.[Footnote 14] During our audit 
of the Foundation's fiscal years 2010 and 2009 financial statements, 
we found that the Foundation had taken action to fully address 11 of 
the 16 recommendations from our prior audit (see enclosure 1). The 5 
recommendations that remained open as of May 6, 2011, the completion 
date of our fiscal year 2010 financial statement audit, relate to 
recording financial transactions, review of bank reconciliations, 
access to check stock, and accounting for contributions receivable. 

* Recording financial transactions. Although the Foundation made 
progress in addressing our recommendation to review and update its 
accounting policies and procedures, several other issues we identified 
during our fiscal year 2009 audit, and additional issues we identified 
during our fiscal year 2010 audit as discussed earlier in this report, 
require further updates to the Foundation's policies and procedures. 
Additionally, while the Foundation took steps to further develop its 
staff's knowledge and skills in accounting and financial reporting for 
not-for-profit organizations by purchasing a financial and accounting 
manual for not-for-profit entities to be used as a resource in 
assisting Foundation staff in preparing the Foundation's financial 
statements and note disclosures, the Foundation has yet to revise its 
policies and procedures to address staff training requirements related 
to accounting and financial reporting. 

* Review of bank reconciliations. The Foundation made progress in 
addressing our recommendation regarding the review of bank 
reconciliations by developing policies and procedures requiring the 
National Director to review and sign off on the bank reconciliations. 
However, the procedures do not require the National Director to 
include the date of review to prove that the review was timely. 

* Access to check stock. The Foundation took steps to address our 
recommendations regarding access to its stock of checks. The 
Foundation established policies and procedures requiring that checks 
be kept in a secure location that is accessible by only the Controller 
and Director of Operations. However, during our fiscal year 2010 
audit, we found that the keys to the filing cabinet drawer containing 
the check stock were accessible to all employees. Therefore, the check 
stock was not in a secure location and further efforts are needed for 
the Foundation to improve physical safeguards related to access to the 
check stock. 

* Accounting for contributions receivable. The Foundation took steps 
to address our recommendation regarding accounting for contributions 
receivable by developing policies and procedures requiring that a 
comparison of the subsidiary and general ledger for contributions 
receivable be performed on a monthly basis. However, the Foundation 
did not include in its policies and procedures requirements to 
document this monthly comparison. 

Foundation Comments and Our Evaluation: 

The Foundation stated that it is pleased that GAO recognized the 
progress made in each of these areas during the fiscal year 2010 
audit, and noted that several additional measures have been taken 
during the current fiscal year to address the open recommendations. 
The Foundation stated that it plans additional steps to further 
strengthen its procedures in these areas in the immediate future. The 
Foundation also noted that it continues to review, update, and modify 
existing policies to best serve its participants. We will evaluate the 
effectiveness of the Foundation's corrective actions during our fiscal 
year 2011 financial audit. 

This report is intended for use by Congressional Award Foundation 
management and the Foundation's Board of Directors. This report is a 
matter of public record, and its distribution is not limited. The 
report will be available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

We acknowledge and appreciate the cooperation and assistance provided 
by the Foundation's management and staff during our audit of the 
Foundation's fiscal years 2010 and 2009 financial statements. If you 
have any questions about this report or need assistance in addressing 
these issues, please contact me at (202) 512-3406 or 
sebastians@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. GAO staff who made major contributions to this report are 
Peggy Smith, Assistant Director; Bethany Smith; and Marci Goasdone. 

Sincerely yours, 

Signed by: 

Steven J. Sebastian:
Director:
Financial Management and Assurance: 

Enclosures - 2: 

[End of section] 

Enclosure I: Status of Recommendations from GAO's 2009 Management 
Report to the Foundation: 

Table 1 presents the status of the 16 recommendations initially 
reported in GAO's September 9, 2010, management report to the 
Congressional Award Foundation (the Foundation). The recommendations 
are grouped by the internal control issues presented in the report. 

Table 1: Status of Recommendations from GAO's 2009 Management Report 
at the End of GAO's Audit of the Foundation's Fiscal Year 2010 
Financial Statements: 

Audit area: Recording financial transactions: 

1. Conduct a review of the Foundation's current accounting policies 
and procedures and update them as necessary; 
Year initially reported: 2009; 
Status of corrective action per GAO: In progress. 

2. Establish and document policies and procedures to ensure that staff 
receive training aimed at developing knowledge and skills in 
accounting and financial reporting for nonprofit organizations; 
Year initially reported: 2009; 
Status of corrective action per GAO: In progress. 

3. Institute a management review process for the Foundation's draft 
financial statements that is effective in identifying material 
misstatements; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

Audit area: Support for adjusting journal entries: 

4. Expand policies and procedures to ensure that all adjusting entries 
are properly documented, supported, reviewed, and approved by 
management; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

Audit area: Review of bank reconciliations: 

5. Document in the Foundation's policies and procedures requirements 
for a timely investigation and resolution of reconciling items, such 
as outstanding checks, in its bank reconciliation process; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

6. Include requirements in the Foundation's policies and procedures 
for management to review, sign, and date bank reconciliations 
indicating management's review for accuracy and completeness; 
Year initially reported: 2009; 
Status of corrective action per GAO: In progress. 

Audit area: Use of personal credit cards and check signing procedures: 

7. Reassess the Foundation's practice of relying on the use of the 
National Director's personal credit card to transact Foundation 
business; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

8. Take steps to obtain a business credit card to support the 
Foundation's business operations as determined by the Foundation's 
business needs; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

9. Institute policies and procedures on the use of that business 
credit card once acquired; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

10. Expand policies and procedures for reviewing and authorizing 
payment for expenses incurred by the National Director to require 
another individual from the Board of Directors to cosign checks over 
$2,500 payable to the National Director; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

Audit area: Access to check stock: 

11. Include in the Foundation's policies and procedures requirements 
for physically safeguarding assets and limiting access to only 
authorized staff; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

12. Identify a secure location to store its check stock that is known 
and accessible only to senior management and staff responsible for 
handling the Foundation's disbursements; 
Year initially reported: 2009; 
[Empty]; 
Status of corrective action per GAO: In progress. 

Audit area: Review of cash deposits: 

13. Enhance policies and procedures over the bank deposit process by 
requiring that the National Director sign and date the deposits; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

Audit area: Accounting for contributions receivable: 

14. Establish formal policies and procedures to ensure that pledges 
are timely and consistently recorded on the subsidiary ledger and the 
general ledger as contributions receivable; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

15. Include in the Foundation's policies and procedures requirements 
to document the monthly reconciliation between the subsidiary ledger 
and the general ledger for contributions receivable and resolve any 
discrepancies identified; 
Year initially reported: 2009; 
Status of corrective action per GAO: In progress. 

16. Expand policies and procedures to require routine monitoring and 
assessing of the collectibility of outstanding receivables; 
Year initially reported: 2009; 
Status of corrective action per GAO: Completed. 

Source: GAO analysis of Foundation data. 

[End of table] 

Enclosure II: Comments from the Congressional Award Foundation: 

Congressional Award: 
379 Ford House Office Building: 
Washington, DC 20515: 
(202) 226-0130: 
Fax: (202) 225-0331: 
Mailing Address: 
Post Office Box 77440: 
Washington, DC 20013: 

August 30, 2011: 

Mr. Steven Sebastian: 
Director: 
Financial Management and Assurance: 
Governmental Accountability Office: 
441 G. Street, NW: 
Washington, DC 20548: 

Dear Mr. Sebastian: 

Thank you for the opportunity to review and comment on the Management 
Report: Opportunities for Improvements in the Congressional Award 
Foundation's Internal Controls and Accounting Procedures. We are 
pleased that the GAO found the fiscal year 2010 financial statements 
to be presented fairly and that there were no reportable instances of 
noncompliance with laws and regulations. 

During the course of the audit, the GAO recognized that the Foundation 
took a number of actions to address the material weakness identified 
during the 2010 audit, however, believes that certain control 
deficiencies over the Foundation's financial reporting process still 
remained in fiscal year 2010, even though they no longer constituted a 
material weakness. We are continuing to work diligently to ascertain 
that all necessary measures are carried out to address these issues 
and fulfill fiduciary responsibilities, as discussed below. 

As we continue to experience growth in program participation amount 
youth, assessment of our systems and procedures remains an ongoing 
process to deliver the program in the best possible manner. We 
appreciate the opportunity to strengthen the Foundation's ability to 
make this program a national opportunity, especially given the 
continued limited resources at hand. 

Year-end Expense Accruals: 

GAO Recommendation: The Foundation should modify its documented 
accounting policies and procedures to address the year-end accrual of 
expenses, which should stipulate that expenses be recognized and a 
liability incurred when goods or services have been received. 

Congressional Award Foundation Response: The Foundation agrees with the
recommendation. The Foundation is drafting policies and procedures to 
ensure that only those expenses are recognized when the goods or 
services have been received. Upon completion of these changes, the new 
policy will be approved by the Board of Directors. 

Status: 

The Board of Directors will meet to discuss the newly drafted policies 
and procedures relating to this issue in September 2011. 

Reconciliation and Supervisory Review Process: 

GAO Recommendation: The Foundation should: (1) modify its documented 
accounting policies and procedures to require routine reconciliation 
and supervisory review of the prepaid insurance amortization schedule 
supporting transactional activity to be recorded in the general ledger 
to ensure that transactions are recorded appropriately and (2) modify 
its documented accounting policies and procedures to require that 
supervisory review of the depreciation and amortization and costs of 
direct benefit to donor schedules supporting transactional activity be 
recorded in the general ledger to ensure that transactions are 
recorded appropriately. 

Congressional Award Foundation Response: The Foundation agrees with the
recommendations. The Foundation is drafting policies and procedures to 
ensure that routine reconciliations and supervisory review of (1) the 
prepaid insurance amortization, (2) the depreciation amortization of 
assets and (3) costs of direct benefits to donors is performed on a 
routine basis. Upon completion of these changes, the new policy will 
be approved by the Board of Directors. 

Status: 

The Board of Directors will meet to discuss the newly drafted policies 
and procedures relating to this issue in September 2011. 

Recording Silent Auction Revenue: 

GAO Recommendation: The Foundation should modify its existing 
accounting policies and procedures to include guidance and 
requirements for the recording of silent auction revenue, which should 
require that the revenue be recorded at fair value when items are 
donated and subsequently adjusted to the amount received when the 
silent auction is held and donors have purchased the items.
Congressional Award Foundation Response: The Foundation agrees with the
recommendation. Upon completion of these changes, the new policy will 
be approved by the Board of Directors. 

Status: 

The Board of Directors will meet to discuss the newly drafted policies 
and procedures relating to this issue in September 2011. 

Status of Fiscal Year 2009 Audit Recommendations: 

During the course of the 2009 audit, the GAO recommended five 
corrective actions which relate to (1) review and update accounting 
policies and procedures (2) continual training of staff, (3) review of 
bank reconciliations, (4) access to check stock, and (5) accounting 
for contributions receivable. We are pleased that the GAO found there 
to be progress in each of these areas during the 2010 audit, and we 
are delighted to report that several additional measures have been 
taken during the current fiscal year to address these concerns. We 
recognize that additional steps can and will be taken to further 
strengthen these procedures in the immediate future. The Foundation 
continues to review, update and modify existing policies to best serve 
our participants. 

If you have any questions, please contact me at (202) 226-0130. 

Sincerely, 

Signed by: 

Erica Wheelan Heyse: 
National Director: 

[End of section] 

Footnotes: 

[1] GAO, Financial Audit: Congressional Award Foundation's Fiscal 
Years 2010 and 2009 Financial Statements, [hyperlink, 
http://www.gao.gov/products/GAO-11-597] (Washington, D.C.: May 12, 
2011). 

[2] GAO, Financial Audit: Congressional Award Foundation's Fiscal 
Years 2009 and 2008 Financial Statements, [hyperlink, 
http://www.gao.gov/products/GAO-10-646] (Washington, D.C.: May 14, 
2010). 

[3] A material weakness is a deficiency, or a combination of 
deficiencies, in internal control such that there is a reasonable 
possibility that a material misstatement of the entity's financial 
statements will not be prevented, or detected and corrected on a 
timely basis. A deficiency in internal control exists when the design 
or operation of a control does not allow management or employees, in 
the normal course of performing their assigned functions, to prevent 
or detect and correct misstatements on a timely basis. 

[4] GAO, Management Report: Opportunities for Improvements in the 
Congressional Award Foundation's Internal Controls and Accounting 
Procedures, [hyperlink, http://www.gao.gov/products/GAO-10-964R] 
(Washington, D.C.: Sept. 9, 2010). 

[5] A significant deficiency is a deficiency, or combination of 
deficiencies, in internal control that is less severe than a material 
weakness, yet important enough to merit attention by those charged 
with governance. 

[6] An accrued expense is an expense incurred but not yet paid at the 
statement date. 

[7] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[8] A prepaid expense is a type of current asset that is expected to 
be consumed during the normal operating cycle of the business, such as 
insurance, deposits for fund-raising events, and operating supplies. 

[9] Amortization is the process of allocating the acquisition costs of 
intangible assets to the periods benefited by the use of the assets. 

[10] Depreciation is the process of allocating the costs of tangible 
assets to those periods expected to benefit from the use of the assets. 

[11] Costs of direct benefits to donors are the actual costs of items 
and services of value, such as meals and tickets, given to 
participants at special events, providing them with a direct benefit. 

[12] Silent auction items are the donated materials that are sold at a 
fund-raising event in an auction where sealed bids are submitted. 

[13] An in-kind contribution is a noncash gift, such as goods or 
services donated to a not-for-profit organization, which may be 
transferred to other resource providers (ultimate resource providers 
or recipients) during fund-raising events. These in-kind items should 
be reported as contributions and measured at fair value when 
originally received by a not-for-profit organization. The difference 
between the amount received for those items from the ultimate resource 
providers (recipients) and the fair value of the in-kind items when 
originally contributed to the not-for-profit organization should be 
recognized as adjustments to the original contributions when the items 
are transferred to the ultimate resource providers (recipients). 

[14] [hyperlink, http://www.gao.gov/products/GAO-10-964R]. 

[End of section] 

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