2023-001 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI084507-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
In accordance with the Uniform Guidance §200.405, if costs benefit multiple programs, the costs should be allocated to the programs based on the proportional benefit. Per the Uniform Guidance §200.413, direct costs are those costs that can be identified specifically or directly assigned to such activities relatively easily with a high degree of accuracy. Additionally, Uniform Guidance §200.302 states that the non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award.
Condition:
During our examination of the Company’s internal control over compliance and compliance with the allowable costs/cost principles of the program, we identified one expense item amounting to $170 allocated to the program. A supporting invoice amounting to $3,500 was provided by the client, but the basis and calculation of the amount allocated to the program was not provided. The Organization did not maintain adequate documentation supporting this allocation expense claimed under the grant.
Cause:
Policies and procedures were not appropriately adhered to in instance noted to ensure that supporting documentation was maintained correctly to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program.
Effect:
The Company was unable to provide supporting documentation to support the basis and calculation of the amount charged to the program for us to conclude whether the expense was properly allocated to the program.
Questioned Costs:
Known questioned costs of $170 in relation to our sample population. Unable to determine unknown questioned costs on the untested population.
Context:
We tested a sample of 40 items and found one exception amounting to $170 as noted in the condition. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management implements a process by which the Organization maintains a separate file with the records for each individual invoice, including supporting allocations, to be included in future submissions to ensure all expenses can be supported.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-002 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI083607-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation.
Condition:
During our testing of personnel costs, we noted that one employee was improperly classified as an hourly employee instead of a salary-based employee which led to the employee being paid $200 more per paycheck for four pay periods.
Cause:
The overpayment was due to human error caused by the Human Resource clerk. The employee sampled was a salaried employee, however, in the timekeeping system the employee was classified as an hourly employee in error. This led to payroll not being able to review and make adjustments to this employee’s hours (related to any leave taken during the pay period) when payroll ran the timekeeping system report for salary employees and led to the employee being overpaid.
Effect or Potential Effect:
This resulted to the questioned costs noted above.
Questioned Costs:
Known questioned costs of $800 in relation to our sample. Unable to determine unknown questioned costs.
Context:
We tested a sample of 40 items and found one employee exception as noted in the condition. The sampled employee occurred twice in sampled items that were tested during the audit and based on information reviewed, the total overpayment to this employee amounted to $800. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior processing and payment to employees. This also assists in ensuring that only allowable costs are charged to the program.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-003 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI084507-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation.
Condition:
During our testing of personnel costs, we noted that one employee received a full bi-weekly pay even after termination. This resulted to an overpayment to the employee amounting to $6,923 which was charged to the program.
Cause:
The overpayment was due to an oversight and payroll missing to update the employee’s status to terminated in the payroll system.
Effect or Potential Effect:
This resulted to the questioned costs noted above.
Questioned Costs:
Known questioned costs of $6,923 in relation to our sample. Unable to determine unknown questioned costs.
Context:
We tested a sample of 40 items and found one exception amounting to $6,923 as noted in the condition. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior to processing and payment to employees. Management should also consider automating the process, where possible, to avoid human errors in the process. This also assists in ensuring that only allowable costs are charged to the program.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-001 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI084507-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
In accordance with the Uniform Guidance §200.405, if costs benefit multiple programs, the costs should be allocated to the programs based on the proportional benefit. Per the Uniform Guidance §200.413, direct costs are those costs that can be identified specifically or directly assigned to such activities relatively easily with a high degree of accuracy. Additionally, Uniform Guidance §200.302 states that the non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award.
Condition:
During our examination of the Company’s internal control over compliance and compliance with the allowable costs/cost principles of the program, we identified one expense item amounting to $170 allocated to the program. A supporting invoice amounting to $3,500 was provided by the client, but the basis and calculation of the amount allocated to the program was not provided. The Organization did not maintain adequate documentation supporting this allocation expense claimed under the grant.
Cause:
Policies and procedures were not appropriately adhered to in instance noted to ensure that supporting documentation was maintained correctly to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program.
Effect:
The Company was unable to provide supporting documentation to support the basis and calculation of the amount charged to the program for us to conclude whether the expense was properly allocated to the program.
Questioned Costs:
Known questioned costs of $170 in relation to our sample population. Unable to determine unknown questioned costs on the untested population.
Context:
We tested a sample of 40 items and found one exception amounting to $170 as noted in the condition. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management implements a process by which the Organization maintains a separate file with the records for each individual invoice, including supporting allocations, to be included in future submissions to ensure all expenses can be supported.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-002 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI083607-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation.
Condition:
During our testing of personnel costs, we noted that one employee was improperly classified as an hourly employee instead of a salary-based employee which led to the employee being paid $200 more per paycheck for four pay periods.
Cause:
The overpayment was due to human error caused by the Human Resource clerk. The employee sampled was a salaried employee, however, in the timekeeping system the employee was classified as an hourly employee in error. This led to payroll not being able to review and make adjustments to this employee’s hours (related to any leave taken during the pay period) when payroll ran the timekeeping system report for salary employees and led to the employee being overpaid.
Effect or Potential Effect:
This resulted to the questioned costs noted above.
Questioned Costs:
Known questioned costs of $800 in relation to our sample. Unable to determine unknown questioned costs.
Context:
We tested a sample of 40 items and found one employee exception as noted in the condition. The sampled employee occurred twice in sampled items that were tested during the audit and based on information reviewed, the total overpayment to this employee amounted to $800. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior processing and payment to employees. This also assists in ensuring that only allowable costs are charged to the program.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.
2023-003 – Allowable Cost/Cost Principles – Internal Control Over Compliance –Noncompliance
Information on Federal Program:
U.S. Department of Health and Human Services
ALN Number: 93.243
ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National
Significance
Grant Award Number: 1H79TI084507-01
Contract Period: 07/01/2022 - 6/30/2023
Criteria:
The 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards. The OMB Compliance Supplement, Part 3 – Compliance Requirements, Allowable Cost/Cost Principles notes that “Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.” Further, the Uniform Guidance Section §200.403(g) states that for costs to be allowable under federal awards, they must be adequately documented, and there must be sufficient documentation.
Condition:
During our testing of personnel costs, we noted that one employee received a full bi-weekly pay even after termination. This resulted to an overpayment to the employee amounting to $6,923 which was charged to the program.
Cause:
The overpayment was due to an oversight and payroll missing to update the employee’s status to terminated in the payroll system.
Effect or Potential Effect:
This resulted to the questioned costs noted above.
Questioned Costs:
Known questioned costs of $6,923 in relation to our sample. Unable to determine unknown questioned costs.
Context:
We tested a sample of 40 items and found one exception amounting to $6,923 as noted in the condition. This is a condition identified per review of the Organization’s compliance with specified requirements using a statistically valid sample.
Recommendation:
In order to facilitate accurate reporting and compliance with terms and conditions of federal awards, we recommend management to enhance controls related to payroll processing to ensure that payroll is accurate prior to processing and payment to employees. Management should also consider automating the process, where possible, to avoid human errors in the process. This also assists in ensuring that only allowable costs are charged to the program.
Views of Responsible Official and Planned Corrective Action:
The Company agrees with the finding identified. The Company’s response to the finding is described in the accompanying management’s corrective action plan.