Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 200.414(f) states that recipients may elect to charge a de minimis rate of up to 10 percent of modified total direct costs (MTDC). 2 CFR 200.1 “Modified Total Direct Cost (MTDC)” excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $50,000.
Condition: During testing of indirect costs, 4 of the 4 samples tested erroneously included rental costs in the calculation of Modified Total Direct Costs, resulting in an overcharge of indirect costs to the program.
Questioned costs: None.
Context: For allowable costs (indirect), a sample of 4 was made from a population of 12 reimbursement requests for the major program. Of the 4 sampled, all rental costs included in the calculation of Modified Total Direct Costs, resulting in a slightly higher indirect cost calculation.
Cause: There is a misunderstanding of which costs should be excluded from the MTDC for this specific contract. Occupancy / Space Rental costs are identified but are not removed during the calculation of indirect costs.
Effect: Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations.
Repeat Finding: 2023-002
Recommendation: CLA recommends that CCS work with the USCCB to update the Reimbursement Request form to include a section that removes items of selected cost from the calculation of indirect costs.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 200.414(f) states that recipients may elect to charge a de minimis rate of up to 10 percent of modified total direct costs (MTDC). 2 CFR 200.1 “Modified Total Direct Cost (MTDC)” excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $50,000.
Condition: During testing of indirect costs, 4 of the 4 samples tested erroneously included rental costs in the calculation of Modified Total Direct Costs, resulting in an overcharge of indirect costs to the program.
Questioned costs: None.
Context: For allowable costs (indirect), a sample of 4 was made from a population of 12 reimbursement requests for the major program. Of the 4 sampled, all rental costs included in the calculation of Modified Total Direct Costs, resulting in a slightly higher indirect cost calculation.
Cause: There is a misunderstanding of which costs should be excluded from the MTDC for this specific contract. Occupancy / Space Rental costs are identified but are not removed during the calculation of indirect costs.
Effect: Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations.
Repeat Finding: 2023-002
Recommendation: CLA recommends that CCS work with the USCCB to update the Reimbursement Request form to include a section that removes items of selected cost from the calculation of indirect costs.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 180.300 indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In a statistically valid sample, CLA tested three covered transactions for ALN 21.027, four for ALN 64.033, and three for ALN 93.676, resulting in 1, 2, and 1 covered transactions, respectively (a total of three vendors, as one deficient covered transaction was tested for both 64.033 and 93.676),
Condition (Continued): lacked documentation to show if a suspension and debarment check had been performed prior to entering into the covered transaction.
Questioned costs: None
Context: For 21.027, the procurement was for general organizational purposes, so costs were charged to a general account and then partially allocated to the federal program. Because it was not a cost directly procured for the program, the suspension and debarment check procedures were missed.
For the shared selection for 64.033/93.676, the contract was a 48-month service agreement for copier service and supplies. The cost was miscalculated as being less than $25,000, therefore an exclusion check was not performed.
The second deficiency for 64.033 was for a contract initiated in 2019. Since then, the organization moved from paper files to electronic file management. Although older paper files are still kept, this particular document was not able to be found.
Cause: There is a misunderstanding that costs that are not directly procured for a federal program may be subject to suspension and debarment checks and a misunderstanding that the full contract cost should be considered when determining if a contract is a covered transaction. There is inadequate document management for historic paper files.
Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, CCS is at risk of noncompliance with federal suspension and debarment requirements.
Repeat Finding: 2023-004
Recommendation: CLA recommends performing suspension and debarment checks on all vendors that may be paid for (even if only in part) with federal funds, if the full value of the contract is likely to exceed $25,000. Additional checks should be performed on a regular basis (recommended annually) so that changes to vendor status are caught timely. This may require modification to organizational policies and training amongst staff who perform procurement activities.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR part 200.430(g)(1), "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Furthermore, 2 CFR 200.430(g)(1)(vi) indicates that these records must "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 a 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".
Condition: (Aging) In a statistically valid sample, one of 40 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
(93.676) In a statistically valid sample, one of 60 payroll expenditures tested was in excess of the hours worked to the major program, per the employee's approved timesheet.
Questioned costs: None
Context: (Aging) In the deficient sample tested, an additional 10.98 hours were charged to the major program that should have been booked to a non-program code, per the approved timesheet. This was due to an allocation setup error in the payroll software. This setup issue only affected one employee, and the full-year impact was immaterial to the program.
(93.676) In the deficient sample tested, an additional .88 hours were charged to the major program that should have been booked to another program code not belonging to the major program, per the approved timesheet. This was due to an allocation setup error in the payroll software. The allocation setup was corrected after the prior year audit, but due to timing of the audit recommendations, the issue persisted into part of FY24. The full-year impact was immaterial to the program.
Cause: Excessive wages were booked to the major program due to an allocation setup error in the payroll software. The employees in question should have been moved to a holding home department. However, when that process was done for all other employees, these employees were missed.
Effect: Inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. This can also lead to overcharging or undercharging the federal grant, which may result in penalties or repayment obligations.
Repeat Finding: 2023-001
Recommendation: CLA recommends implementing a review process over ADP allocations to ensure that employees who work across various programs have their wages allocated accurately based on the documented time and effort spent on each program.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 200.414(f) states that recipients may elect to charge a de minimis rate of up to 10 percent of modified total direct costs (MTDC). 2 CFR 200.1 “Modified Total Direct Cost (MTDC)” excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $50,000.
Condition: During testing of indirect costs, 4 of the 4 samples tested erroneously included rental costs in the calculation of Modified Total Direct Costs, resulting in an overcharge of indirect costs to the program.
Questioned costs: None.
Context: For allowable costs (indirect), a sample of 4 was made from a population of 12 reimbursement requests for the major program. Of the 4 sampled, all rental costs included in the calculation of Modified Total Direct Costs, resulting in a slightly higher indirect cost calculation.
Cause: There is a misunderstanding of which costs should be excluded from the MTDC for this specific contract. Occupancy / Space Rental costs are identified but are not removed during the calculation of indirect costs.
Effect: Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations.
Repeat Finding: 2023-002
Recommendation: CLA recommends that CCS work with the USCCB to update the Reimbursement Request form to include a section that removes items of selected cost from the calculation of indirect costs.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR 200.414(f) states that recipients may elect to charge a de minimis rate of up to 10 percent of modified total direct costs (MTDC). 2 CFR 200.1 “Modified Total Direct Cost (MTDC)” excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $50,000.
Condition: During testing of indirect costs, 4 of the 4 samples tested erroneously included rental costs in the calculation of Modified Total Direct Costs, resulting in an overcharge of indirect costs to the program.
Questioned costs: None.
Context: For allowable costs (indirect), a sample of 4 was made from a population of 12 reimbursement requests for the major program. Of the 4 sampled, all rental costs included in the calculation of Modified Total Direct Costs, resulting in a slightly higher indirect cost calculation.
Cause: There is a misunderstanding of which costs should be excluded from the MTDC for this specific contract. Occupancy / Space Rental costs are identified but are not removed during the calculation of indirect costs.
Effect: Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations.
Repeat Finding: 2023-002
Recommendation: CLA recommends that CCS work with the USCCB to update the Reimbursement Request form to include a section that removes items of selected cost from the calculation of indirect costs.
Views of responsible officials: There is no disagreement with the audit finding.