Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.
Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.