Criteria or specific requirement: According to 2 CFR §200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to 2 CFR §200.405(d), if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit However, when those proportions cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. According to 2 CFR §200.431(b), the cost of fringe benefits in the form of regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave, holidays, court leave, military leave, administrative leave, and other similar benefits, are allowable if all of the following criteria are met: (1) They are provided under established written leave policies; (2) The costs are equitably allocated to all related activities, including Federal awards; and, (3) The accounting basis (cash or accrual) selected for costing each type of leave is consistently followed by the recipient or subrecipient or a specified grouping of employees. Condition: During our testing, we noted that the Department did not allocate leave to grants in accordance with the time and effort employees spent on the grants. Questioned costs: $887 Context: During our testing of twenty payroll disbursements, we noted that the Department had a net undercharge of $887 to eight grants. Cause: The Department was unaware of the federal regulations pertaining to leave allocations. Effect: The auditor noted instances of noncompliance. Noncompliance results in possible under or over charges to the grant. Repeat Finding: No. Recommendation: We recommend that the Department develop and implement a written policy for leave allocation consistent with federal regulations. Also, we recommend that the Department provides training to ensure employees understand and comply with the written policy. Views of responsible officials and planned corrective actions: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.405(d). Corrective action was taken. The Department revised the procedures and will no longer charge any type of leave activity to a grant, effective July 1, 2025, and for the foreseeable future. An email was sent out by the CFO on June 26, 2025 advising all Department employees about this change. The Federal Aid Cost Tracking System (FACTS) has also been changed to block access to all grants for any leave time reporting code entries. If a system is developed in the future to enable the allocation of leave consistent will the federal regulations, training will be provided for all employees. Responsible Employee Position: CFO Timeline: July 31, 2026
Criteria or specific requirement: According to 2 CFR §200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to 2 CFR §200.403(f), except where otherwise authorized by statute, costs must meet not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period. Condition: During our testing of drawdowns related to matching, we noted that the Department did not adjust its reimbursement request to account for a duplicate travel reimbursement. Questioned costs: $169 Context: The Department processed a travel reimbursement twice, resulting in a duplicate payment of $225 to the employee. The employee reimbursed the Department for this duplicate payment. However, the Department did not adjust its reimbursement request to reflect the credit in the financial records. Cause: The Department was unaware that the query used for the reimbursement request excluded the credit. Effect: The auditor noted an instance of noncompliance. Noncompliance results in possible under or over charges to the grant. Repeat Finding: No. Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Views of responsible officials and planned corrective actions: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.403(f). Corrective action will be taken. The Department revised the policies and procedures for cash disbursements within the Administrative Services Division. Effective immediately, upon running the monthly query of federal expenditures for the cash reimbursement for federal grants, the Federal Financial Analyst will submit the query to the Budget Director and the Accountant/Auditor. A reconciliation to the General Ledger will be completed by them prior to the Federal Financial Analyst requesting the cash reimbursement. Responsible Employee Position: CFO Timeline: July 31, 2026