Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable payroll documentation for the period August
1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities
Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant.
Management charged payroll to the program based on budget.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must
be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s financial
management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently or
accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation for
personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
Corporation for National and Community Services
Assistance Listing Numbers 94.006 – AmeriCorps State and National
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Indirect Costs)
Repeat Finding: No
Condition:
The Organization was unable to provide applicable indirect costs rationale documentation for the
period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls
over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to
provide the approved indirect rate for the various locations to support the actual indirect cost rate
charged.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program compliance
requirements.
Per AmeriCorps general terms and conditions, the recipient must maintain financial management
systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems
must be capable of distinguishing expenditures attributable to this award from expenditures not
attributable to this award. The systems must be able to identify costs by program year and by
budget category, and to differentiate between direct and indirect costs. For all recipient’s
financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR
Part 200.
Cause:
The Organization did not have adequate controls over the rationale of indirect cost process,
therefore recording and retention of supporting documentation was not properly adhered to in
accordance with Uniform Guidance.
Effect or Potential Effect:
Indirect costs were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Questioned Costs:
Unknown.
Recommendation:
We recommend the Organization establish and implement controls to properly document the
indirect costs rationale and approved rate determination to charge to the grant.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.
U.S. Department of Treasury
Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable
Costs/Cost Principle (Payroll)
Repeat Finding: No
Condition:
During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For
16 selections, we did not receive the timesheets to substantiate the amount charged to the grant.
We were unable to determine whether the salaries that were charged to the program accurately
reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned
to a single cost objective for the grant, thus, not showing the effort by funding source, which is
needed to calculate the actual effort for this Federal grant.
Criteria:
The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and
maintain internal controls designed to reasonably ensure compliance with Federal statutes,
regulations, and terms and conditions of the Federal award.
The characteristics of internal controls are presented in the context of the components of internal
controls discussed in Internal Control-Integrated Framework (COSO Report), published by the
Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report
provides a framework for organizations to design, implement, and evaluate control that will
facilitate compliance with the requirements of Federal laws, regulations, and program
compliance requirements.
Per 2 CFR section 200.430(a)(3)(i):
(a) General. Compensation for personal services includes all remuneration, paid currently
or accrued, for services of employees rendered during the period of performance under the
Federal award, including but not necessarily limited to wages and salaries. Compensation
for personal services may also include fringe benefits which are addressed in §200.431
Compensation—fringe benefits. Costs of compensation are allowable to the extent that they
satisfy the specific requirements of this part, and that the total compensation for individual
employees:
(1) Is reasonable for the services rendered and conforms to the established written policy of
the non-Federal entity consistently applied to both Federal and non-Federal activities.
(2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules
or written policies and meets the requirements of Federal statute, where applicable; and
(3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for
salaries and wages must be based on records that accurately reflect the work performed.
These records must:
(i) Be supported by a system of internal controls which provides reasonable assurance that
the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the
official records of the non-Federal entity; (iii) Reasonably reflect the total activity for
which the employee is compensated by the non-Federal entity, not exceeding 100% of
compensated activities; (iv) Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but may include the use of
subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with
the established accounting policies and practices of the non-Federal entity; and (vi)
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.
Cause:
The Organization did not have adequate controls over the time and effort process, therefore
recording and retention of supporting documentation was not properly adhered to in accordance
with Uniform Guidance.
Effect or Potential Effect:
Salaries and wages were not properly supported by a system of internal controls which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and
wage charges were not able to be reconciled to the time distribution records.
Questioned Costs:
Unknown.
Recommendation:
We recommend that the Organization implement policies and procedures to track, calculate and
document adjustments from budget salary charges to actual after-the-fact charges that should be
charged to the Federal award based on the employee time distribution records. This needs to be
performed at least on an annual basis.