Columbus Neighborhood Health Center, Inc.
dba PrimaryOne Health
Corrective Action Plan
Year Ended December 31, 2023
Contact Information:
Charleta B. Tavares, Chief Executive Officer
614. 859. 1946
ctavares@primaryonehealth.org
Audit period: January 1, 2023 – December 31, 2023
Finding 2023-001 –...
Columbus Neighborhood Health Center, Inc.
dba PrimaryOne Health
Corrective Action Plan
Year Ended December 31, 2023
Contact Information:
Charleta B. Tavares, Chief Executive Officer
614. 859. 1946
ctavares@primaryonehealth.org
Audit period: January 1, 2023 – December 31, 2023
Finding 2023-001 – Allowable Costs (Time and Effort)
Recommendation: Management should establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allowable costs which includes ensuring time and effort charges are based on records that accurately reflect the work performed.
Action planned/take in response to finding:
1. Implementation of Time and Effort Reporting System: The organization has begun to establish and implement a robust time and effort reporting system in compliance with 2 CFR 200.430. This system will:
a. Accurately reflect the distribution of employee time across different federal grants.
b. Track employee hours worked, allocate wages based on grant activities, and ensure the proper alignment of salaries to the work performed.
c. Provide documentation supporting time allocation between different federal and non-federal activities.
2. Training for Payroll and Grants Management Staff: All payroll, human resources, and finance staff will undergo mandatory training on:
a. Time and effort reporting requirements under federal guidelines.
b. The correct procedures for allocating wages to federal grants, including compliance with Uniform Guidance (2 CFR 200).
3. Updating Policies and Procedures: The organization will update internal policies to reflect compliance with the Uniform Guidance, particularly regarding payroll documentation and time and effort allocation. This will include:
a. Establishing written procedures on tracking employee work hours and effort reporting.
b. Implementing monthly or quarterly reviews to ensure payroll costs are appropriately charged to federal awards.
4. Periodic Internal Audits: The organization will conduct periodic internal audits to ensure continued compliance with federal requirements, especially as it relates to payroll and time tracking. Any discrepancies will be promptly corrected to avoid future findings.
Planned completion date for corrective action plan: December 31, 2024