Finding No. 2023-003: Internal Control over Payroll – Significant Deficiency in Internal Control over Compliance
U.S. Agency for International Development, USAID Foreign Assistant for Programs Overseas, Assistance Listing Number 98.001.
Criteria
Section 200.405 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) indicates that a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. This standard is met, among other things, if the cost charged is incurred specifically for the federal award. Also, under cost principles established by 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and be incorporated into the official records of the non-Federal entity.
Context
During our testing of payroll expenditures, we noted an instance for one employee where the time worked on the award did not have support to document that the payroll expenditure was properly approved and an instance where a bonus was awarded to an employee, where the allocation for time worked on the federal award for the specific pay period was used as the allocable base for the overall bonus instead of the period to which the bonus was related. The total amount recorded to the grant related to this was $2,563.
Cause
There was a breakdown in internal control where one employee’s timesheet was not reviewed by their supervisor. Also, when reviewing the allocable charges to the federal award, there was a breakdown in internal control when preparing the allocation for the pro-rated salary charges incurred related to the federal award.
Effect
The amount charged to the federal award was not properly authorized. If the compensation costs allocated to the grant cannot be supported in accordance with the Uniform Guidance, the granting agency could determine that these costs are not allowable.
Questioned Costs
The amount did not exceed $25,000 and therefore is not required to be reported.
Recommendation
The Organization’s program staff and management should ensure that the amounts charged to the federal award are properly approved and accurate. Monthly reconciliation of all expenses, including of salaries charged to program versus actual hours incurred should be performed timely.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan
Finding No. 2023-004: Internal Control over Period of Performance – Significant Deficiency in Internal Control over Compliance
U.S. Agency for International Development, USAID Foreign Assistant for Programs Overseas, Assistance Listing Number 98.001.
Criteria
As per the Code of Federal Regulations (CFR) § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). This includes ensuring that expenses are incurred during the period of performance stated in the federal award.
Context
During our testing over the period of performance, we noted 3 payroll charges that were recorded to the grant after the period of performance on the grant award had ended. The Organization was able to replace the $1,824 in payroll charges with eligible consultant charges incurred during the period to support the recognition of this total.
Cause
This was due to a breakdown in internal control over the review and approval of charges incurred by the appropriate personnel for amounts charged against the federal award.
Effect
Charging expenditures incurred outside of the award period can result in refusal of these reimbursements by the federal grantor as well as the possibility of loss of grant funding for future periods.
Questioned Costs
None
Recommendation
We recommend that the Organization review and enhance its current internal control procedures over its financial close process specifically related to the period of performance around federal awards to ensure that there are procedures in place to ensure that the expenditures claimed fall within the appropriate period of the federal award and are recognized in the correct period in accordance with generally accepted accounting principles on a timely basis.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan
Finding No. 2023-005: Internal Control over Preparation of Schedule of Expenditures of Federal Awards (“SEFA”) – Significant Deficiency in Internal Control over Compliance
Criteria
Uniform Guidance prescribes the required Schedule of Expenditures of Federal Awards (SEFA) contents and delineates how or what is deemed to be expenditures for purposes of completing the SEFA.
Context
During our testing, when comparing the amount of the federal expenditures recorded to the general ledger, we noted a difference in the overall federal expenditures and the related federal revenue recorded.
Cause
There was a breakdown in internal controls over reconciling the supporting schedule used as part of the audit testing, to amounts recorded to the SEFA. This was due to expenditures recognized in the prior years that were not included on the SEFA, but were claimed on the requests for reimbursement from the federal agency.
Effect
A difference noted between expenditures and revenue recognized could lead to awards being over or under drawn and not in compliance with respective awards.
Questioned Costs
None
Recommendation
To ensure adequate internal controls over the preparation of the SEFA, we recommend that the Organization enhance internal controls over the preparation of the SEFA to ensure that it is prepared by one individual with another individual reviewing the underlying support to ensure completeness and accuracy.
Views of Responsible Officials
See Corrective Action Plan
Finding No. 2023-003: Internal Control over Payroll – Significant Deficiency in Internal Control over Compliance
U.S. Agency for International Development, USAID Foreign Assistant for Programs Overseas, Assistance Listing Number 98.001.
Criteria
Section 200.405 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) indicates that a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. This standard is met, among other things, if the cost charged is incurred specifically for the federal award. Also, under cost principles established by 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and be incorporated into the official records of the non-Federal entity.
Context
During our testing of payroll expenditures, we noted an instance for one employee where the time worked on the award did not have support to document that the payroll expenditure was properly approved and an instance where a bonus was awarded to an employee, where the allocation for time worked on the federal award for the specific pay period was used as the allocable base for the overall bonus instead of the period to which the bonus was related. The total amount recorded to the grant related to this was $2,563.
Cause
There was a breakdown in internal control where one employee’s timesheet was not reviewed by their supervisor. Also, when reviewing the allocable charges to the federal award, there was a breakdown in internal control when preparing the allocation for the pro-rated salary charges incurred related to the federal award.
Effect
The amount charged to the federal award was not properly authorized. If the compensation costs allocated to the grant cannot be supported in accordance with the Uniform Guidance, the granting agency could determine that these costs are not allowable.
Questioned Costs
The amount did not exceed $25,000 and therefore is not required to be reported.
Recommendation
The Organization’s program staff and management should ensure that the amounts charged to the federal award are properly approved and accurate. Monthly reconciliation of all expenses, including of salaries charged to program versus actual hours incurred should be performed timely.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan
Finding No. 2023-004: Internal Control over Period of Performance – Significant Deficiency in Internal Control over Compliance
U.S. Agency for International Development, USAID Foreign Assistant for Programs Overseas, Assistance Listing Number 98.001.
Criteria
As per the Code of Federal Regulations (CFR) § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). This includes ensuring that expenses are incurred during the period of performance stated in the federal award.
Context
During our testing over the period of performance, we noted 3 payroll charges that were recorded to the grant after the period of performance on the grant award had ended. The Organization was able to replace the $1,824 in payroll charges with eligible consultant charges incurred during the period to support the recognition of this total.
Cause
This was due to a breakdown in internal control over the review and approval of charges incurred by the appropriate personnel for amounts charged against the federal award.
Effect
Charging expenditures incurred outside of the award period can result in refusal of these reimbursements by the federal grantor as well as the possibility of loss of grant funding for future periods.
Questioned Costs
None
Recommendation
We recommend that the Organization review and enhance its current internal control procedures over its financial close process specifically related to the period of performance around federal awards to ensure that there are procedures in place to ensure that the expenditures claimed fall within the appropriate period of the federal award and are recognized in the correct period in accordance with generally accepted accounting principles on a timely basis.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan
Finding No. 2023-005: Internal Control over Preparation of Schedule of Expenditures of Federal Awards (“SEFA”) – Significant Deficiency in Internal Control over Compliance
Criteria
Uniform Guidance prescribes the required Schedule of Expenditures of Federal Awards (SEFA) contents and delineates how or what is deemed to be expenditures for purposes of completing the SEFA.
Context
During our testing, when comparing the amount of the federal expenditures recorded to the general ledger, we noted a difference in the overall federal expenditures and the related federal revenue recorded.
Cause
There was a breakdown in internal controls over reconciling the supporting schedule used as part of the audit testing, to amounts recorded to the SEFA. This was due to expenditures recognized in the prior years that were not included on the SEFA, but were claimed on the requests for reimbursement from the federal agency.
Effect
A difference noted between expenditures and revenue recognized could lead to awards being over or under drawn and not in compliance with respective awards.
Questioned Costs
None
Recommendation
To ensure adequate internal controls over the preparation of the SEFA, we recommend that the Organization enhance internal controls over the preparation of the SEFA to ensure that it is prepared by one individual with another individual reviewing the underlying support to ensure completeness and accuracy.
Views of Responsible Officials
See Corrective Action Plan