Audit of the Millennium Challenge Corporation’s Financial Statements, Internal Controls, and Compliance for the Fiscal Years Ending September 30, 2016, and 2015

We recommend that MCC's Department of Administration and Finance and the chief financial officer update its Expense Accruals Financial Management Procedure Manual to a) Require justification and analysis to be documented, supported, and approved by MCC's management when deviating from its accrual policy and procedures. This should include MCC verification of information provided by the Millennium Challenge Account to support the accrual. b) Include the guidance provided to the Millennium Challenge Accounts on how and what each Millennium Challenge Account will provide as support in addressing the reasonableness of their accrual.

We recommend that MCC's Department of Administration and Finance and the chief financial officer conduct a comprehensive review and formalize the Grant Accrual Validation Whitepaper as an official policy and procedures document that includes: a) Establishing a documented supervisory review of the grant accrual validation to ensure that the validation is performed correctly and is in accordance with MCC's validation methodology. b) Establishing procedures that clearly state how the accrual validation will be carried out when a Millennium Challenge Account is closed out and no longer exists.

We recommend that MCC's Department of Administration and Finance and the chief financial officer establish internal control procedures to properly review the accounting and reporting of funds returned by the Millennium Challenge Accounts and foreign governments, and other transactions that are not routinely prepared in its financial operations to ensure that these transactions are recorded correctly and in accordance with United States Standard General Ledger.

We recommend that MCC's Department of Administration and Finance and the chief financial officer establish an internal control process to ensure that financial statements are prepared in accordance with the most current version of Office of Management and Budget A-136.

We recommend that MCC's Department of Administration and Finance and the chief financial officer conduct a quarterly reconciliation between the status of budgetary resources and the Office of Management and Budget SF-132, Apportionment and Reapportionment Schedule.

We recommend that MCC's Department of Administration and Finance and the chief financial officer implement a management control to properly review and approve unapportioned funds by programs/projects at the fund level before entries are made.

We recommend that MCC's Department of Administration and Finance and the chief financial officer implement a management control to review the impact of funds unapportioned at the fund level before apportionment and recoveries adjustments are recorded.

We recommend that MCC's Department of Administration and Finance and the chief financial officer continue requiring all compact obligating documents be accompanied by an entry-into-force memo prior to recognizing obligation.