Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200, Subpart E, charges to Federal awards must be adequately documented and incurred during the approved budget period, amongst other factors. Per 2 CFR §200.430(i), Compensation - personal services, Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
• Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
• Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and
• Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. In addition, there was no evidence that actual incurred expenditures were used as a basis for allocating indirect costs to the grant using the negotiated indirect cost rate.
Questioned Costs: $132,823 (total employee salaries, wages and benefits charged to the program) and $40,427 (total indirect costs charged to the program in excess of actual incurred expenditures to the program)
Context: For our direct labor and indirect costs allowable costs samples, Army management indicated that all 7 direct labor expenditure selections totaling $13,819 and indirect costs of $79,252 were allocated to the program based on budgeted percentages. Army management also indicated that there was no evidence that a subsequent review of budget estimates was performed for all of the selections.
Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant.
Effect: Personnel and indirect costs charged to federal awards without appropriate documentation may be subject to disallowance.
Repeat Finding: Yes – Finding 2022-02.
Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, the salary and wage allocations to the grant, and allocation of indirect costs are charged to the grant using an appropriate base, are appropriately documented and accurately reflect the work performed.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200.318, General procurement standards, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at a minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website.
Condition/Context: For our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor.
Questioned Costs: None noted.
Cause: The entity has written policies for construction procurements, including requirements to obtain at least 2 competitive bids for projects over $5,000 and two proposals for architectural services over $100,000. The entity’s policies also require use of American Institute of Architects contract agreements for construction projects among other requirements. However, the entity does not have policies and procedures designed for procurements under the Uniform Guidance, and therefore, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner.
Effect: Costs charged to federal awards without appropriate documentation of procurement policies and processes may be subject to disallowance.
Repeat Finding: No.
Recommendation: We recommend developing written procurement policies in accordance with the Uniform Guidance and implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend retaining documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200, Subpart E, charges to Federal awards must be adequately documented and incurred during the approved budget period, amongst other factors. Per 2 CFR §200.430(i), Compensation - personal services, Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
• Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
• Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and
• Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. In addition, there was no evidence that actual incurred expenditures were used as a basis for allocating indirect costs to the grant using the negotiated indirect cost rate.
Questioned Costs: $132,823 (total employee salaries, wages and benefits charged to the program) and $40,427 (total indirect costs charged to the program in excess of actual incurred expenditures to the program)
Context: For our direct labor and indirect costs allowable costs samples, Army management indicated that all 7 direct labor expenditure selections totaling $13,819 and indirect costs of $79,252 were allocated to the program based on budgeted percentages. Army management also indicated that there was no evidence that a subsequent review of budget estimates was performed for all of the selections.
Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant.
Effect: Personnel and indirect costs charged to federal awards without appropriate documentation may be subject to disallowance.
Repeat Finding: Yes – Finding 2022-02.
Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, the salary and wage allocations to the grant, and allocation of indirect costs are charged to the grant using an appropriate base, are appropriately documented and accurately reflect the work performed.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200.318, General procurement standards, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at a minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website.
Condition/Context: For our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor.
Questioned Costs: None noted.
Cause: The entity has written policies for construction procurements, including requirements to obtain at least 2 competitive bids for projects over $5,000 and two proposals for architectural services over $100,000. The entity’s policies also require use of American Institute of Architects contract agreements for construction projects among other requirements. However, the entity does not have policies and procedures designed for procurements under the Uniform Guidance, and therefore, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner.
Effect: Costs charged to federal awards without appropriate documentation of procurement policies and processes may be subject to disallowance.
Repeat Finding: No.
Recommendation: We recommend developing written procurement policies in accordance with the Uniform Guidance and implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend retaining documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200, Subpart E, charges to Federal awards must be adequately documented and incurred during the approved budget period, amongst other factors. Per 2 CFR §200.430(i), Compensation - personal services, Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
• Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
• Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and
• Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. In addition, there was no evidence that actual incurred expenditures were used as a basis for allocating indirect costs to the grant using the negotiated indirect cost rate.
Questioned Costs: $132,823 (total employee salaries, wages and benefits charged to the program) and $40,427 (total indirect costs charged to the program in excess of actual incurred expenditures to the program)
Context: For our direct labor and indirect costs allowable costs samples, Army management indicated that all 7 direct labor expenditure selections totaling $13,819 and indirect costs of $79,252 were allocated to the program based on budgeted percentages. Army management also indicated that there was no evidence that a subsequent review of budget estimates was performed for all of the selections.
Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant.
Effect: Personnel and indirect costs charged to federal awards without appropriate documentation may be subject to disallowance.
Repeat Finding: Yes – Finding 2022-02.
Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, the salary and wage allocations to the grant, and allocation of indirect costs are charged to the grant using an appropriate base, are appropriately documented and accurately reflect the work performed.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200.318, General procurement standards, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at a minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website.
Condition/Context: For our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor.
Questioned Costs: None noted.
Cause: The entity has written policies for construction procurements, including requirements to obtain at least 2 competitive bids for projects over $5,000 and two proposals for architectural services over $100,000. The entity’s policies also require use of American Institute of Architects contract agreements for construction projects among other requirements. However, the entity does not have policies and procedures designed for procurements under the Uniform Guidance, and therefore, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner.
Effect: Costs charged to federal awards without appropriate documentation of procurement policies and processes may be subject to disallowance.
Repeat Finding: No.
Recommendation: We recommend developing written procurement policies in accordance with the Uniform Guidance and implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend retaining documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200, Subpart E, charges to Federal awards must be adequately documented and incurred during the approved budget period, amongst other factors. Per 2 CFR §200.430(i), Compensation - personal services, Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
• Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
• Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and
• Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. In addition, there was no evidence that actual incurred expenditures were used as a basis for allocating indirect costs to the grant using the negotiated indirect cost rate.
Questioned Costs: $132,823 (total employee salaries, wages and benefits charged to the program) and $40,427 (total indirect costs charged to the program in excess of actual incurred expenditures to the program)
Context: For our direct labor and indirect costs allowable costs samples, Army management indicated that all 7 direct labor expenditure selections totaling $13,819 and indirect costs of $79,252 were allocated to the program based on budgeted percentages. Army management also indicated that there was no evidence that a subsequent review of budget estimates was performed for all of the selections.
Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant.
Effect: Personnel and indirect costs charged to federal awards without appropriate documentation may be subject to disallowance.
Repeat Finding: Yes – Finding 2022-02.
Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, the salary and wage allocations to the grant, and allocation of indirect costs are charged to the grant using an appropriate base, are appropriately documented and accurately reflect the work performed.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Federal Agency: Department of Treasury
Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Funding Year(s): 2023-2026
Criteria: Per 2 CFR §200.318, General procurement standards, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at a minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website.
Condition/Context: For our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor.
Questioned Costs: None noted.
Cause: The entity has written policies for construction procurements, including requirements to obtain at least 2 competitive bids for projects over $5,000 and two proposals for architectural services over $100,000. The entity’s policies also require use of American Institute of Architects contract agreements for construction projects among other requirements. However, the entity does not have policies and procedures designed for procurements under the Uniform Guidance, and therefore, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner.
Effect: Costs charged to federal awards without appropriate documentation of procurement policies and processes may be subject to disallowance.
Repeat Finding: No.
Recommendation: We recommend developing written procurement policies in accordance with the Uniform Guidance and implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend retaining documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks.
Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.