According to 2 CFR 200.430(i), charges to federal awards for salaries and wages
must be based on records that accurately reflect the work performed.
Specifically:
- Employees who work 100% on a single federal award must have certifications
stating that all time was dedicated to the grant, signed by the employee or a
supervisor with firsthand knowledge, prepared at least semi-annually.
- Employees whose time is split among multiple activities must maintain time
and effort reports reflecting actual hours worked in a manner consistent with 2
CFR 200.430(g)(vi).
- All compensation costs charged to federal awards must be supported by
appropriate documentation that complies with the federal cost principles.During the year ended June 30, 2024, we noted the following:
- Employees who charged 100% of their time to the grant lacked required
certifications or timecards documenting that their time was spent exclusively on
grant-related activities.
- In several instances, no timecards were available.
- In other cases, available timecards showed no evidence of review or approval.
- Employees who allocated only a portion of their time to the grant tracked hours
worked on the grant, multiplied by their hourly rate, rather than maintaining
records in compliance with 2 CFR 200.430(g)(vi), which requires a system of
records that accurately reflects actual work performed.
- Certain compensation costs totaling $50,000 were charged to the grant without
any supporting documentation. These amounts represent questioned costs.
Under 2 CFR 200.318-326, non-federal entities must adhere to procurement
standards for purchases made with federal funds. Key requirements include:
- Full and Open Competition: Procurement transactions must be conducted to
ensure open competition and prevent practices that may unduly restrict
competition (2 CFR 200.319(a)).
- Documentation of Procurement History: Entities must maintain records that
detail the procurement history, including the rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price (2 CFR 200.318(i)).
- Use of Non-Competitive Procurement: Non-competitive procurement is only
allowed under limited circumstances, such as when the item is available from a
single source, there is a public emergency, or after solicitation of multiple
sources, competition is deemed inadequate (2 CFR 200.320(c)).The Organization incurred expenditures of approximately $620,000 for the
renovation of a community center using federal funds under the SLFRF program.
The Organization received two bids for the renovation project. However, full
documentation of the process was not maintained.
Cause: The Organization did not establish or follow sufficient internal controls to ensure
compliance with federal procurement requirements, including maintaining the
required documentation for procurement activities.
Possible effect: The lack of procurement documentation creates a significant risk that
noncompliant practices occurred, such as non-competitive procurement or
payments exceeding fair market value.
According to 2 CFR 200.430(i), charges to federal awards for salaries and wages
must be based on records that accurately reflect the work performed.
Specifically:
- Employees who work 100% on a single federal award must have certifications
stating that all time was dedicated to the grant, signed by the employee or a
supervisor with firsthand knowledge, prepared at least semi-annually.
- Employees whose time is split among multiple activities must maintain time
and effort reports reflecting actual hours worked in a manner consistent with 2
CFR 200.430(g)(vi).
- All compensation costs charged to federal awards must be supported by
appropriate documentation that complies with the federal cost principles.During the year ended June 30, 2024, we noted the following:
- Employees who charged 100% of their time to the grant lacked required
certifications or timecards documenting that their time was spent exclusively on
grant-related activities.
- In several instances, no timecards were available.
- In other cases, available timecards showed no evidence of review or approval.
- Employees who allocated only a portion of their time to the grant tracked hours
worked on the grant, multiplied by their hourly rate, rather than maintaining
records in compliance with 2 CFR 200.430(g)(vi), which requires a system of
records that accurately reflects actual work performed.
- Certain compensation costs totaling $50,000 were charged to the grant without
any supporting documentation. These amounts represent questioned costs.
Under 2 CFR 200.318-326, non-federal entities must adhere to procurement
standards for purchases made with federal funds. Key requirements include:
- Full and Open Competition: Procurement transactions must be conducted to
ensure open competition and prevent practices that may unduly restrict
competition (2 CFR 200.319(a)).
- Documentation of Procurement History: Entities must maintain records that
detail the procurement history, including the rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price (2 CFR 200.318(i)).
- Use of Non-Competitive Procurement: Non-competitive procurement is only
allowed under limited circumstances, such as when the item is available from a
single source, there is a public emergency, or after solicitation of multiple
sources, competition is deemed inadequate (2 CFR 200.320(c)).The Organization incurred expenditures of approximately $620,000 for the
renovation of a community center using federal funds under the SLFRF program.
The Organization received two bids for the renovation project. However, full
documentation of the process was not maintained.
Cause: The Organization did not establish or follow sufficient internal controls to ensure
compliance with federal procurement requirements, including maintaining the
required documentation for procurement activities.
Possible effect: The lack of procurement documentation creates a significant risk that
noncompliant practices occurred, such as non-competitive procurement or
payments exceeding fair market value.