Audit 306700

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.403(e) requires that costs be determined in accordance with GAAP to be allowable under federal awards. Condition: A 30-month contract was fully paid and charged to the federal award while 6 months of the contract were incurred during the fiscal year. Cause: The prepaid contract was recorded as an expense in the general ledger. The reviewer did not consider the contract term for GAAP and compliance requirements. Effect or Potential Effect: Questioned costs may be disallowed and repayment made. Questioned Costs: $54,000; 24 months of the prepaid contract not incurred. Context: A sample of 30 disbursements totaling $275,477 was selected for testing from a population of 147 disbursements totaling $788,841. The testing found 2 disbursements related to the prepaid contract and were not in compliance. Repeat Finding: No. Recommendation: Transactions should be recorded in accordance with GAAP with a review and approval for financial reporting as well as for compliance with allowability requirements. Training on cost principles per the Uniform Guidance should be provided to the finance department and program managers. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is receiving training.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: There are no documented procurement procedures that meet the requirements of 2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not specifically include standards of conduct covering conflicts of interest for procurement. There are no designed and implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through 200.327. For three significant transactions tested there were no documentation of the rationale for the method, documentation to support a required procurement method used, contractor selections or rejections, suspension and debarment, and bases for contract prices. The only support documented are the invoices. Total procurements were $482,904. Cause: The organization began charging procurement transactions in the current year to federal awards. The organization’s staff did not understand how to document the procurement history. Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid. Questioned Costs: $365,501; total of the three significant transactions tested. Repeat Finding: No. Recommendation: The organization should develop and document procurement procedures that meet state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to include standards of conduct for those involved in procuring and to include organizational conflicts of interest. Internal controls should be designed, implemented, and documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the procurement history including rationale for the method, procurement method support, contract selections and rejections, suspension and debarment, and bases for contract prices should be documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procurement and conflict-of-interest policies.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition and Context: No supporting documentation was provided for the three subrecipients. No subaward agreements included all required information and none were executed and signed. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were performed and documented. There was no documentation of whether the 3 subrecipients were expected to/are being audited per the Uniform Guidance. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid. Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year. Repeat Finding: No. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing written procedures.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.303(a) requires a non-federal entity to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: 8 out of 30 disbursements charged to the federal award were not documented as reviewed and approved. 3 of the 8 were modified or entered by journal entry and reviewed by the same individual. 5 out of 8 were the result of the accounts payable bills module not configured to set up controls to review and approve transactions. Cause: Edits and journal entries by accounting personnel were not subject to review. The accounts payable bills module was not configured for a review and approval process. Effect or Potential Effect: Noncompliance with federal statutes, regulations, and the terms and conditions of the federal award may not be prevented or detected and corrected. Questioned Costs: None. Context: 30 disbursement items out of 149 were tested. Repeat Finding: No. Recommendation: Additional procedures should be designed, implemented, and documented for allowable costs to ensure documentation of review and approval of allowable costs to be charged to the federal award. The accounting system configurations should be modified to require segregation of duties for all transactions. For journal entries, a documented review and approval should be performed by a finance committee member on a monthly basis. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a review process over accounts payable and journal entries.

Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Significant Deficiency: As discussed in Finding 2023-004, salaried employees reported exactly 8 hours every day for the pay period and numerous employees reported the exact same split of activities every day of the pay period. Because employees are not reporting all time for activities in which they are compensated, costs charged to federal programs may not be equitable and allowable. Procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Repeat Finding: No Criteria: Charges to awards for salaries and wages are to be supported by approved timecards and activity reports. Accurate supporting backup includes timecards/activity reports signed by employees and their supervisors. Time and effort documentation must reasonably reflect the total activity for which the employee is compensated for. Condition: Timecards for numerous salaried employees reported exactly 8 hours every day for the pay period. In addition, numerous employees reported the exact same split of activities every day of the pay period. Cause: A written policy and procedure over time and effort reporting was not designed and implemented. Effect or Potential Effect: Failure to maintain appropriate records on eligible expenses may result in repayment for the portion of funds in question. Recommendation: Timecards should reflect all time or 100% effort of each employee’s total hours actually spent on work within the scope of his or her employment regardless of how many or how few hours an employee works. Effort certification must reflect actual work performed and cannot be budget driven or assigned. A written time and effort policy and procedures should be designed and implemented to meet grantor requirements and recordkeeping requirements of the organization. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a cost allocation plan and review process over time and effort.