Audit 9001

Allowable Costs – Ryan White Part B HIV Care Formula Grants – Federal Assistance Listing Number 93.917; Award Period: Year ended June 30, 2022; Pass-through entity names: Virginia Department of Health and Northern Virginia Regional Commission Recommendation: We recommend the Organization implement a process to first record time into the payroll system based on timesheets, then further implement a review process to compare the payroll register hours to the approved timesheets. Views of Responsible Officials: The auditee agrees with this recommendation and has taken the necessary steps to prevent a re-occurrence. Lack of timesheets and pay rates resulted in the inability to show that time and payroll were accurately recorded. This resulted in additional procedures during the audit process being performed to obtain reasonable assurance over these balances. Criteria: Per 2 CFR §200.430(i), non-federal entities are required to maintain records that accurately reflect work performed. These records must be supported by a system of internal control which provides reasonable assurance that the time being charged is accurate, allowable and properly allocated, are incorporated in the official records, such as payroll records, reasonably reflect the employee’s total activity, provide a time or percentage breakdown on all activities, both federally and non-federally funded, for the employee, and comply with the non-federal entity’s pre-established accounting practices and procedures. Condition: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. Cause: There is a lack of review of payroll registers to compare to timesheets to ensure the proper amount of hours are submitted for reimbursement. Effect: The Organization billed the incorrect amount of payroll and related costs to the federal program, resulting in questioned costs. Questioned Costs: The amount of payroll and related costs discovered to be incorrect was a net amount of $25, which when projected onto the remaining payroll and related costs that were not tested, amounted to $1,038. Context: Timesheets of numerous employees were found to not match the hours used in calculating payroll to be submitted for reimbursement to the grant.

Eligibility – Ryan White Part B HIV Care Formula Grants – Federal Assistance Listing Number 93.917; Award Period: Year ended June 30, 2022; Pass-through entity names: Virginia Department of Health and Northern Virginia Regional Commission Criteria: Eligibility requirements under the HIV Care Formula Grants state that the eligibility verification must include documentation of each source of income provided to determine if the household income is equal to or below 500% of the Federal Poverty Level. The Organization completes an income eligibility form and obtains backup documentation for the information included on the form. Condition: The Organization had contradicting support for the income eligibility documentation for two clients. All documentation supported the conclusion that the client was eligible based on their income, however the lack of consistent evidence resulted in the conclusion that proper review and approval of this documentation is not occurring. Cause: The Organization did not have policies and procedures operating effectively to monitor the accurate completion of the income eligibility form. Effect: The lack of effective review of eligibility documentation could result in an ineligible client receiving services under the federal award. Questioned Costs: None noted. Context: Two clients had inconsistent documentation regarding income eligibility, however all income documentation resulted in the clients being eligible on the basis of income. Recommendation: We recommend the Organization implement a process for the proper review of income eligibility forms by comparing to the support provided for income. Views of Responsible Officials: The auditee disagrees with this finding. The clients reviewed were income eligible. Client eligibility is also checked by each funding source that funds each program.

Allowable Costs – Ryan White Part B HIV Care Formula Grants – Federal Assistance Listing Number 93.917; Award Period: Year ended June 30, 2022; Pass-through entity names: Virginia Department of Health and Northern Virginia Regional Commission Recommendation: We recommend the Organization implement a process to first record time into the payroll system based on timesheets, then further implement a review process to compare the payroll register hours to the approved timesheets. Views of Responsible Officials: The auditee agrees with this recommendation and has taken the necessary steps to prevent a re-occurrence. Lack of timesheets and pay rates resulted in the inability to show that time and payroll were accurately recorded. This resulted in additional procedures during the audit process being performed to obtain reasonable assurance over these balances. Criteria: Per 2 CFR §200.430(i), non-federal entities are required to maintain records that accurately reflect work performed. These records must be supported by a system of internal control which provides reasonable assurance that the time being charged is accurate, allowable and properly allocated, are incorporated in the official records, such as payroll records, reasonably reflect the employee’s total activity, provide a time or percentage breakdown on all activities, both federally and non-federally funded, for the employee, and comply with the non-federal entity’s pre-established accounting practices and procedures. Condition: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. Cause: There is a lack of review of payroll registers to compare to timesheets to ensure the proper amount of hours are submitted for reimbursement. Effect: The Organization billed the incorrect amount of payroll and related costs to the federal program, resulting in questioned costs. Questioned Costs: The amount of payroll and related costs discovered to be incorrect was a net amount of $25, which when projected onto the remaining payroll and related costs that were not tested, amounted to $1,038. Context: Timesheets of numerous employees were found to not match the hours used in calculating payroll to be submitted for reimbursement to the grant.

Eligibility – Ryan White Part B HIV Care Formula Grants – Federal Assistance Listing Number 93.917; Award Period: Year ended June 30, 2022; Pass-through entity names: Virginia Department of Health and Northern Virginia Regional Commission Criteria: Eligibility requirements under the HIV Care Formula Grants state that the eligibility verification must include documentation of each source of income provided to determine if the household income is equal to or below 500% of the Federal Poverty Level. The Organization completes an income eligibility form and obtains backup documentation for the information included on the form. Condition: The Organization had contradicting support for the income eligibility documentation for two clients. All documentation supported the conclusion that the client was eligible based on their income, however the lack of consistent evidence resulted in the conclusion that proper review and approval of this documentation is not occurring. Cause: The Organization did not have policies and procedures operating effectively to monitor the accurate completion of the income eligibility form. Effect: The lack of effective review of eligibility documentation could result in an ineligible client receiving services under the federal award. Questioned Costs: None noted. Context: Two clients had inconsistent documentation regarding income eligibility, however all income documentation resulted in the clients being eligible on the basis of income. Recommendation: We recommend the Organization implement a process for the proper review of income eligibility forms by comparing to the support provided for income. Views of Responsible Officials: The auditee disagrees with this finding. The clients reviewed were income eligible. Client eligibility is also checked by each funding source that funds each program.