2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer
2023—002—ELIGIBILTIY Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period: Multiple; Budget period: Multiple Questioned Costs: Approximately $1,616 Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The income verification form for stipend volunteers seems to be based on the volunteers’ estimation and certification, without providing proof of income 2 out of 25 volunteers tested did not pass the age test and should have not been compensated (total amount paid to them for stipend, travel and meals was approximately $1,615.95) Context Out of 25 volunteers tested (43% of the entire population), 2 did not pass the age test. Proof of income was not in the files just the form completed and signed by the volunteers. Criteria To be eligible to be paid a stipend, Foster Grandparents and Senior Companions must be at least 55 years old; meet income guidelines; and be physically, mentally, and emotionally capable of serving on a person-to-person basis. Income eligibility is based on the applicant’s total annual income (including the total annual income of the applicant’s spouse), less allowable medical expenses. To be income-eligible, an applicant’s income must fall at or below 200 percent of the poverty level as annually established by the Department of Health and Human Services for the state in which he or she resides. Foster Grandparents and Senior Companion programs may enroll persons who are at least 55 years old, but who do not meet the income guidelines as non-stipend Foster Grandparents or Senior Companions (45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J). Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authorized Representative
2023—003—SPECIAL TESTS AND PROVISIONS Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period: Multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The Institute does not appear to have a conflict-of-interest statement or form for the staff/volunteers to sign/certify that they are not related to any of the Board members or staff, etc. or a process to notify Americorps in cases where these relationships exist. 14 out of 25 volunteers did not have a 100% name match in the background checking forms Context Out of 25 volunteers tested (43% of the entire population), 14 did not have complete names in the background check forms. Note: the background checks were redone during 2024. Criteria The grant requires that the National Service Criminal History Checks are completed in accordance with AmeriCorps regulations (i.e., completing the required checks and making an eligibility determination within the required timelines and documenting them correctly). The grantee needs to use AmeriCorps approved vendors for the background checks and provide evidence that the first and last names used on the name-based checks reflect the current name of the individual. All documents used to determine an individual first and last name must be consistent with the grant recipient policies and procedures. Also, persons selected for project staff positions shall not be related by blood or marriage to other project staff, sponsor staff or officers, or members of the sponsor Board of Directors, unless there is written concurrence from the Advisory Council or community group established by the sponsor under subpart B of this part, and with notification to AmeriCorps. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, president and Authorized Representative.
2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer
2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer
2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer
2023—002—ELIGIBILTIY Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period: Multiple; Budget period: Multiple Questioned Costs: Approximately $1,616 Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The income verification form for stipend volunteers seems to be based on the volunteers’ estimation and certification, without providing proof of income 2 out of 25 volunteers tested did not pass the age test and should have not been compensated (total amount paid to them for stipend, travel and meals was approximately $1,615.95) Context Out of 25 volunteers tested (43% of the entire population), 2 did not pass the age test. Proof of income was not in the files just the form completed and signed by the volunteers. Criteria To be eligible to be paid a stipend, Foster Grandparents and Senior Companions must be at least 55 years old; meet income guidelines; and be physically, mentally, and emotionally capable of serving on a person-to-person basis. Income eligibility is based on the applicant’s total annual income (including the total annual income of the applicant’s spouse), less allowable medical expenses. To be income-eligible, an applicant’s income must fall at or below 200 percent of the poverty level as annually established by the Department of Health and Human Services for the state in which he or she resides. Foster Grandparents and Senior Companion programs may enroll persons who are at least 55 years old, but who do not meet the income guidelines as non-stipend Foster Grandparents or Senior Companions (45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J). Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authorized Representative
2023—003—SPECIAL TESTS AND PROVISIONS Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period: Multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The Institute does not appear to have a conflict-of-interest statement or form for the staff/volunteers to sign/certify that they are not related to any of the Board members or staff, etc. or a process to notify Americorps in cases where these relationships exist. 14 out of 25 volunteers did not have a 100% name match in the background checking forms Context Out of 25 volunteers tested (43% of the entire population), 14 did not have complete names in the background check forms. Note: the background checks were redone during 2024. Criteria The grant requires that the National Service Criminal History Checks are completed in accordance with AmeriCorps regulations (i.e., completing the required checks and making an eligibility determination within the required timelines and documenting them correctly). The grantee needs to use AmeriCorps approved vendors for the background checks and provide evidence that the first and last names used on the name-based checks reflect the current name of the individual. All documents used to determine an individual first and last name must be consistent with the grant recipient policies and procedures. Also, persons selected for project staff positions shall not be related by blood or marriage to other project staff, sponsor staff or officers, or members of the sponsor Board of Directors, unless there is written concurrence from the Advisory Council or community group established by the sponsor under subpart B of this part, and with notification to AmeriCorps. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, president and Authorized Representative.
2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer
2023-001 [2022—002]—ALLOWABLE COSTS AND ACTIVITIES—PAYROLL AND RELATED ITEMS Federal Agency: U.S. Department of Health and Human Services and AmeriCorps- Corporation for National and Community Service Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 and 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and inconsistent allocations were applied to the grants. In some instances, the percentages of allocations calculated in timesheets were incorrect and did not match the allocation in the general ledger. It appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In September 2023, the timesheets were improved, and the allocation seems to match the percentages, however, the formulas seem to calculate the payments based on allocated budget rather than actual hours worked. Context 60 transactions were tested. Out of 60, 27 were payroll and payroll taxes related. 20 payroll transactions out of 27 tested, including wages and payroll taxes, could not be traced in such a manner that provided reasonable assurance that the charges to the grant were accurate and properly allocated. It appears that salaries and taxes are allocated based on budget rather than direct time spent on grant. In some instances, some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0. Criteria According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: We concur with these findings and have redesigned our timekeeping system to comply. Finding resolved timeline: October 2024’Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer