2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2867.10 gives regulatory effect to the Department of Justice for 2 CFR ?180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ?180.200 identifies ?covered transactions? as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR ? 180.215. When a non-Federal entity enters a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (http://sam.gov); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365." The City did not have the proper internal controls in place to verify that all entities, with whom the City had entered covered transactions, had not been suspended or debarred. During testing of the contract expenses for AL #16.922 Equitable Sharing Program Funds grant programs, we noted seven out of eight instances in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor could be provided. Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds. Prior to contracting with vendors that will be paid with federal funds, the City should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ?200.303(a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR ?200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. During testing of payroll expenses for AL #14.218 CDBG Entitlement Grant Cluster, we noted the City utilized employee-completed time-sheets for allocating payroll expenses to the federal program. However, the City?s established internal control procedures did not occur for six out of 40 timesheets. The timesheets did not contain appropriate evidence that the timesheet was reviewed and approved by a supervisor with direct knowledge of the employee?s activities to support proper allocation to the program. We were able to substantiate the related expenses through additional means to support allocation to the federal program. Failure to ensure all time sheets are appropriately approved by a knowledgeable supervisor could result in unallowable costs being allocated to a federal program and could ultimately result in a questioned cost. We recommend the City review established policies and procedures and ensure all timesheets are appropriately reviewed prior to allocation to a federal program.
2 CFR ?2867.10 gives regulatory effect to the Department of Justice for 2 CFR ?180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ?180.200 identifies ?covered transactions? as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR ? 180.215. When a non-Federal entity enters a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (http://sam.gov); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365." The City did not have the proper internal controls in place to verify that all entities, with whom the City had entered covered transactions, had not been suspended or debarred. During testing of the contract expenses for AL #16.922 Equitable Sharing Program Funds grant programs, we noted seven out of eight instances in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor could be provided. Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds. Prior to contracting with vendors that will be paid with federal funds, the City should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.