Audit 319820

Finding: Item 2022-001 – Eligibility: Eligibility for Individuals Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Material Weakness Criteria: The federal program specifies the criteria for determining the individuals or groups of individuals that can participate in the program. Condition/context: Community Service Council of Greater Tulsa, Inc. (the Council) did not have internal controls established for an independent review that the participants accepted into the program met the qualifying criteria. Eligibility may be determined by Council employees or by certain health care facilities. Cause: The Council did not perform an independent review of source data to verify participant eligibility. Effect: Lack of controls in place over acceptance of participants into the program increases the possibility that errors will be made when deciding who is eligible and the accuracy of data input into the system for tracking participants. Questioned cost: Not applicable. Recommendation: We recommend the Council establish a control requiring participants to certify the accuracy of information. Additionally, the Council should have an independent review of source data to verify participants are eligible and the accuracy of data entered into the system for tracking, and such review must be documented. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-001 – Eligibility: Eligibility for Individuals Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Material Weakness Criteria: The federal program specifies the criteria for determining the individuals or groups of individuals that can participate in the program. Condition/context: Community Service Council of Greater Tulsa, Inc. (the Council) did not have internal controls established for an independent review that the participants accepted into the program met the qualifying criteria. Eligibility may be determined by Council employees or by certain health care facilities. Cause: The Council did not perform an independent review of source data to verify participant eligibility. Effect: Lack of controls in place over acceptance of participants into the program increases the possibility that errors will be made when deciding who is eligible and the accuracy of data input into the system for tracking participants. Questioned cost: Not applicable. Recommendation: We recommend the Council establish a control requiring participants to certify the accuracy of information. Additionally, the Council should have an independent review of source data to verify participants are eligible and the accuracy of data entered into the system for tracking, and such review must be documented. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.

Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness   Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.