Audit 368463

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Grants for New and Expanded Services under the Health Center Program and Senior Companion Program Assistance Listing Number: 93.048 Pass-Through: N/A Federal Award Identification Number and Year: All Award #s under ALN 93.048 Award Period: Project period multiple; Budget period: All Projects #s under ALN 93.048 Questioned Costs: None We note over/under-billing by pay period. Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted instances in which timesheets were not approved, and it appears that allocations are based mainly on budget rather than actual direct and indirect time spent on the grant. In July 2024, the timesheets were improved, however the general ledger amount is consistent indicating that the amount in general ledger is based on budget rather than the percentage of hours worked under the grant. Management implemented a true-up process to be able to verify the payroll charged over one year budget period. Note: the timesheet issue is related only to staff paid from multiple sources (5 out of 11 employees). Management progress: The Institute implemented a new timesheet and an annual reconciliation to verify if the allocations are truing up over one year Budget period and to adjust the Budget in the allowed threshold, if needed. Context 60 transactions were tested. Out of 60, 22 were payroll and payroll taxes related. 14 payroll transactions out of 22 tested, including wages and payroll taxes, seem to be allocated based on budget (per each pay period rather than direct time spent on grant. In some instances (paydays), some grants were underbilled and in some instances were overbilled and the net effect of questioned costs summed up close to $0 (if the overall reconciliation was taken in consideration). The Institute implemented one year reconciliation to make sure that the variations net to zero over the budget period. Criteria Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed (e.g., 2 CFR 200.430; for HHS awards, 45 CFR 75.430(i)). Records must be supported by internal controls, reflect total compensated activities, and support allocation among cost objectives. According to §75.430 (i) select standards for documentation of personal expenses are as follows: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 75. A potential effect of noncompliance of the federal award could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of confirmation that the timesheet expenses match the general ledger. Recommendation We recommend the organization prevent recurrence of noncompliance through conducting regular reviews and reconciliations, providing timesheet training and guidance to staff and monitoring compliance. We also recommend a re-design of the timesheets, so grant allocations and calculations for direct and indirect cost are more easily performed and traceable to the grant general ledger. View of Responsible Official: The timesheet implemented in July 2024 properly reflects the actual vs budgeted hours for employees with multiple funding sources. We will continue to analyze discrepancies to determine if budget revisions are necessary. Finding resolved timeline: October 2025 Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer.

2024-002 [2023—002]—ELIGIBILITY Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Please refer to all Award #s under ALN 94.016 Award Period: Project period: Multiple; Budget period: Please refer to all Project #s under ALN 94.016 Questioned Costs: $10,184 Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The income verification form for stipend volunteers seems to be based on the volunteers’ estimation and certification, without providing proof of income Context Out of 4 volunteers tested (reminder volunteers not tested in prior years), four did not have proof that income was verified. Proof of income was not in the files just the form completed and signed by the volunteers. Criteria To be eligible to be paid a stipend, Foster Grandparents and Senior Companions must be at least 55 years old; meet income guidelines; and be physically, mentally, and emotionally capable of serving on a person-to-person basis. Income eligibility is based on the applicant’s total annual income (including the total annual income of the applicant’s spouse) and less allowable medical expenses. To be income-eligible, an applicant’s income must fall at or below 200 percent of the poverty level as annually established by the Department of Health and Human Services for the state in which he or she resides. Foster Grandparents and Senior Companion programs may enroll persons who are at least 55 years old, but who do not meet the income guidelines as non-stipend Foster Grandparents or Senior Companions (45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J). Management progress: subsequently to year ended December 31, 2025, the Institute updated the internal forms asking volunteers to provide adequate proof of income. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: We have undertaken additional training and review of regulations in this area to ensure compliance. Finding resolved timeline: December 1, 2025. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authorized Representative