Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.
Condition: During 2023, the Organization allocated payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and did not have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Subsequent to year end, the Organization had employees complete a 2023 time and effort report. In multiple instances, we noted employees who had left the Organization and thus certain reports were not signed by the employees. We also noted instances of missing reports for employees. The 2023 time and effort reports did not accurately reflect what was charged to the grant during the year.
Questioned Costs: Unknown
Context: The amounts charged to the grant did not represent the actual time and was not tracked properly throughout the year. This resulted from the Organization no having a system of internal control that provided reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause: The Organization was using budgeting amounts and did not have a system in place to charge accurate time.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs.
Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. It is recommended that the Organization implement the time and effort certification reports at least quarterly or utilize timesheets within in payroll system to properly allocated to federal grants. If utilizing certification reports, ensure time and effort reporting charged to the grant is updated on regularly basis.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award.
Condition: During our testing, we noted there was a lack of supporting documentation for certain expenses as well as a lack of review of invoices.
Questioned Costs: Assistance Listing 93.958, Block Grants for Community Mental Health Services: $83,374. Assistance Listing 93.676, Unaccompanied Children Program: $70,990
Context: During our review of charges to the Block Grants for Community Mental Health Services program (Assistance Listing No. 93.958), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 19 expense transactions totaling $83,374 did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose. .
During our review of charges to the Unaccompanied Children Program (Assistance Listing number 93.676), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 37 expense transaction did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose.
Cause: There is not a formal process to ensure all expenditures are documented, maintained, and properly reviewed. The Organization experience turnover in multiple positions in finance during the year which caused the process for filing and maintaining documentation not to be consistent.
Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed.
Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR Part 200 Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of the funds.
Condition: During our testing, we noted the Organization’s draw downs were more than the expenditures on the schedule of federal awards as well as the support provided from the general ledger.
Questioned costs: $339,667
Context: During our testing, it was noted there was a lack of review or approval on the calculation to actual costs incurred.
Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to manage the cash management process.
Recommendation: We recommend the Organization implement a clear approval process and review for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This should involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the Organization enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, and meet its financial obligations.
Grantee Comment: Refer to the Correction Action Plan
Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.
Condition: During 2023, the Organization allocated payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and did not have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Subsequent to year end, the Organization had employees complete a 2023 time and effort report. In multiple instances, we noted employees who had left the Organization and thus certain reports were not signed by the employees. We also noted instances of missing reports for employees. The 2023 time and effort reports did not accurately reflect what was charged to the grant during the year.
Questioned Costs: Unknown
Context: The amounts charged to the grant did not represent the actual time and was not tracked properly throughout the year. This resulted from the Organization no having a system of internal control that provided reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause: The Organization was using budgeting amounts and did not have a system in place to charge accurate time.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs.
Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. It is recommended that the Organization implement the time and effort certification reports at least quarterly or utilize timesheets within in payroll system to properly allocated to federal grants. If utilizing certification reports, ensure time and effort reporting charged to the grant is updated on regularly basis.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award.
Condition: During our testing, we noted there was a lack of supporting documentation for certain expenses as well as a lack of review of invoices.
Questioned Costs: Assistance Listing 93.958, Block Grants for Community Mental Health Services: $83,374. Assistance Listing 93.676, Unaccompanied Children Program: $70,990
Context: During our review of charges to the Block Grants for Community Mental Health Services program (Assistance Listing No. 93.958), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 19 expense transactions totaling $83,374 did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose. .
During our review of charges to the Unaccompanied Children Program (Assistance Listing number 93.676), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 37 expense transaction did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose.
Cause: There is not a formal process to ensure all expenditures are documented, maintained, and properly reviewed. The Organization experience turnover in multiple positions in finance during the year which caused the process for filing and maintaining documentation not to be consistent.
Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed.
Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions.
Grantee Comment: Refer to the Correction Action Plan
Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.
Condition: During 2023, the Organization allocated payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and did not have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Subsequent to year end, the Organization had employees complete a 2023 time and effort report. In multiple instances, we noted employees who had left the Organization and thus certain reports were not signed by the employees. We also noted instances of missing reports for employees. The 2023 time and effort reports did not accurately reflect what was charged to the grant during the year.
Questioned Costs: Unknown
Context: The amounts charged to the grant did not represent the actual time and was not tracked properly throughout the year. This resulted from the Organization no having a system of internal control that provided reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause: The Organization was using budgeting amounts and did not have a system in place to charge accurate time.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs.
Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. It is recommended that the Organization implement the time and effort certification reports at least quarterly or utilize timesheets within in payroll system to properly allocated to federal grants. If utilizing certification reports, ensure time and effort reporting charged to the grant is updated on regularly basis.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award.
Condition: During our testing, we noted there was a lack of supporting documentation for certain expenses as well as a lack of review of invoices.
Questioned Costs: Assistance Listing 93.958, Block Grants for Community Mental Health Services: $83,374. Assistance Listing 93.676, Unaccompanied Children Program: $70,990
Context: During our review of charges to the Block Grants for Community Mental Health Services program (Assistance Listing No. 93.958), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 19 expense transactions totaling $83,374 did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose. .
During our review of charges to the Unaccompanied Children Program (Assistance Listing number 93.676), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 37 expense transaction did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose.
Cause: There is not a formal process to ensure all expenditures are documented, maintained, and properly reviewed. The Organization experience turnover in multiple positions in finance during the year which caused the process for filing and maintaining documentation not to be consistent.
Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed.
Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR Part 200 Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of the funds.
Condition: During our testing, we noted the Organization’s draw downs were more than the expenditures on the schedule of federal awards as well as the support provided from the general ledger.
Questioned costs: $339,667
Context: During our testing, it was noted there was a lack of review or approval on the calculation to actual costs incurred.
Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to manage the cash management process.
Recommendation: We recommend the Organization implement a clear approval process and review for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This should involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the Organization enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, and meet its financial obligations.
Grantee Comment: Refer to the Correction Action Plan
Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.
Condition: During 2023, the Organization allocated payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and did not have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Subsequent to year end, the Organization had employees complete a 2023 time and effort report. In multiple instances, we noted employees who had left the Organization and thus certain reports were not signed by the employees. We also noted instances of missing reports for employees. The 2023 time and effort reports did not accurately reflect what was charged to the grant during the year.
Questioned Costs: Unknown
Context: The amounts charged to the grant did not represent the actual time and was not tracked properly throughout the year. This resulted from the Organization no having a system of internal control that provided reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause: The Organization was using budgeting amounts and did not have a system in place to charge accurate time.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs.
Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. It is recommended that the Organization implement the time and effort certification reports at least quarterly or utilize timesheets within in payroll system to properly allocated to federal grants. If utilizing certification reports, ensure time and effort reporting charged to the grant is updated on regularly basis.
Grantee Comment: Refer to the Correction Action Plan
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award.
Condition: During our testing, we noted there was a lack of supporting documentation for certain expenses as well as a lack of review of invoices.
Questioned Costs: Assistance Listing 93.958, Block Grants for Community Mental Health Services: $83,374. Assistance Listing 93.676, Unaccompanied Children Program: $70,990
Context: During our review of charges to the Block Grants for Community Mental Health Services program (Assistance Listing No. 93.958), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 19 expense transactions totaling $83,374 did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose. .
During our review of charges to the Unaccompanied Children Program (Assistance Listing number 93.676), we selected a sample of 60 expense transactions were tested for Activities Allowed or Unallowed, allowable Costs/cost Principles and 37 expense transaction did not have proper documentation to support the expense being charged to the grant whether it was a missing invoice, or the invoice did not support the grant purpose.
Cause: There is not a formal process to ensure all expenditures are documented, maintained, and properly reviewed. The Organization experience turnover in multiple positions in finance during the year which caused the process for filing and maintaining documentation not to be consistent.
Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed.
Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions.
Grantee Comment: Refer to the Correction Action Plan