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Finding 2025-002: Time and Effort Documentation Name of Contact Person: TRIO Upward Bound Project Director, Vacant. In the Interim, contact will be Dr. Kayla Devora-Jones. Corrective Action: To prevent future occurrences, the College has implemented strengthened safeguards. All Time and Effort repor...
Finding 2025-002: Time and Effort Documentation Name of Contact Person: TRIO Upward Bound Project Director, Vacant. In the Interim, contact will be Dr. Kayla Devora-Jones. Corrective Action: To prevent future occurrences, the College has implemented strengthened safeguards. All Time and Effort reports are now housed in Microsoft Teams with shared access for the TRIO Directors, the supervising Institutional Project Manager, and the Human Resources Payroll Specialist, ensuring clear accountability in the submission and review process. TRIO Directors and the supervising Institutional Project Manager are responsible for the timely completion and submission of all Time and Effort reports, which must now be submitted within five business days following each payroll cycle. Human Resources is responsible for reviewing all submitted reports to verify completeness. This corrective action ensures systematic monitoring, real-time verification, and timely completion of all personnel activity reports. The shared filing structure also eliminates gaps in documentation and has been fully implemented across all four TRIO programs. Proposed Completion Date: 10/31/2025 Anticipated Completion Date: Completed
CORRECTIVE ACTION PLAN Finding 2025-001 – Allowable Costs The District concurs with the finding 2025-001. Corrective Action: The District will implement the following corrective actions to be completed by September 30, 2025: 1.The District will develop and implement new written policies and procedur...
CORRECTIVE ACTION PLAN Finding 2025-001 – Allowable Costs The District concurs with the finding 2025-001. Corrective Action: The District will implement the following corrective actions to be completed by September 30, 2025: 1.The District will develop and implement new written policies and procedures for time and effort reporting. 2.All grant-funded employees will receive training on the new procedures. 3.The District will implement a new system to track and certify employee time. Contact Person: Lou D’Ambro, School Business Administrator (315) 822-2826 ldambro@mmcsd.org
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that...
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements w...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisory approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Material Weakness Item 2025-005 -Activities Allowed and Una/lowed Costs - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 Dur...
Material Weakness Item 2025-005 -Activities Allowed and Una/lowed Costs - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that LBUCC charged salaries to the Section 330 grant based on pre-determined allocations or budget rather than actual hours worked. LBUCC utilized timesheets that reflect the allocations as its time and effort documentation. Recommendation: We recommend that LBUCC implement a time and effort reporting system that tracks actual hours worked on each program or grant. We recommend that they require supervisors to review and approve the actual time spent on grant activities and that such review and approval be documented. Action Taken: LBUCC will implement a time and effort reporting system to include a semi-annual certification for all employees funded by the HRSA 330 grant and a time card reporting system for those funded by multiple grants. Effectivity Date: Time and effort reporting will be implemented in January 2026 and fully in place by 1/31/2026
REFERENCE: 2025-001 – Allowable Costs/Cost Principles HIV Emergency Relief Project Grants (Assistance Listing No. 93.914) Federal Grantor: Health Resources and Services Administration Facility: Bailey-Boushay House Finding: At Bailey-Boushay House, controls over the required allowability criteria wi...
REFERENCE: 2025-001 – Allowable Costs/Cost Principles HIV Emergency Relief Project Grants (Assistance Listing No. 93.914) Federal Grantor: Health Resources and Services Administration Facility: Bailey-Boushay House Finding: At Bailey-Boushay House, controls over the required allowability criteria with regard to payroll expense were not performed and/or documented throughout the year. Corrective Action Plan: At Bailey-Boushay House, each Friday and Monday prior to running payroll, approval reminders are sent to all staff with the time-keeping policy attached. At least two different leaders and/or the scheduling coordinator send these reminders. Staff have been educated on the two-step approval system and it will impact their performance evaluation if there is continued non-compliance. The Finance Manager reviews the timecard allocations and populates the hours charged to the grant per the timecard on to the salary allocation spreadsheet. The salary allocation spreadsheet is utilized in completing the reimbursement request. The timecards and the allocation spreadsheet are included in the reimbursement request. Beginning in January 2026, the salary allocation spreadsheet and timecards will be reviewed and signed off by the Director of Outpatient Programs as part of the reimbursement request approval process. Additionally, timecard approval compliance for prior periods will be reviewed during Bailey-Boushay weekly leadership meetings. Person Responsible: Rob Hays, Executive Director – Bailey-Boushay House Expected Completion: January 2026
Finding 2025-001 – Allowable Costs The BOCES concurs with the finding 2025-001. Corrective Action: The BOCES will implement the following corrective actions to be completed by November 30, 2025: 1. The BOCES will develop and implement new written policies and procedures for time and effort reporting...
Finding 2025-001 – Allowable Costs The BOCES concurs with the finding 2025-001. Corrective Action: The BOCES will implement the following corrective actions to be completed by November 30, 2025: 1. The BOCES will develop and implement new written policies and procedures for time and effort reporting. 2. All grant-funded employees will receive training on the new procedures. 3. The BOCES will implement a new system to track and certify employee time. Contact Person: Daniel Henner, Business Administrator (315) 796-9902 dhenner@herkimer-boces.org
The District will use the Federal Uniform Grant guidance to ensure that the all costs are allowable. Any individual that is charged to a federal grant will keep time and effort reporting documentation.
The District will use the Federal Uniform Grant guidance to ensure that the all costs are allowable. Any individual that is charged to a federal grant will keep time and effort reporting documentation.
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested wh...
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested where the District could not provide evidence of review and approval for grant expenditures. Finally, we identified 3 instances out of 40 selections tested where the hours reported on timesheets did not agree with the hours charged to the grant. The District’s failure to maintain supporting documentation for certain grant expenditures, provide evidence of review and approval, and accurately report time charged to the grant increases the risk of noncompliance with federal requirements under 2 CFR Part 200. These deficiencies create an increased risk of questioned costs which could ultimately lead to disallowed costs and the potential repayment of grant funds to the granting agency. Additionally, inaccurate reporting and weak internal controls diminish the reliability of financial information submitted to the grantor, reduce accountability, and heighten the risk of errors or fraudulent activity. Auditor Recommendation: We recommend that the District review its written policies and procedures over federal awards to ensure that controls are in place that will require that all expenditures for either payroll or disbursements have the appropriate documentation and evidence of review and approval prior to payment. Corrective Action: The District will review its written policies and procedures over federal awards to ensure that all expenditures have the appropriate documentation and evidence of review and approval prior to payment. Responsible Person: Maria Gistinger, Interim Chief Financial Officer Anticipated Completion Date: June 30, 2026
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Alth...
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Although the Organization calculated the capped allowable salaries for each employee, the allocations entered into the payroll system reflected full gross wages rather than the capped amounts, resulting in the excess salaries. Individual(s) Responsible for Corrective Action: Philip Kneer, CFO Brandon Gilbert, Corporate Compliance Officer / Co-Director of HR April Bledsoe, / Co-Director of HR Planned Corrective Action: Integrate automatic HRSA salary cap checks into payroll and HRIS systems. Create salary cap flags that prevent or warn when charges exceed allowable rates. Implement quarterly salary compliance audits comparing employee salaries to HRSA limits. Anticipated Completion Date: Update payroll system control within the HRIS/Payroll system by February 28, 2026 First quarterly salary compliance audit to be completed by February 26, 2026
Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk tha...
Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk that costs may be charged to the program in error. Root Cause Although program coding is built into the payroll system during employee setup, controls were not consistently documented or monitored, particularly for staff working across multiple funding sources and for private school Title I employees. A lack of secondary review allowed for one miscoding error and inconsistent position information between contracts and timesheets. Corrective Actions to Be Taken 1. Payroll Coding Review: Implement a second-level review process, led by the Business Manager, to verify all federal program payroll coding each pay period before submission. 2. Position Alignment: Require a monthly reconciliation of contracted positions against timesheet records to ensure consistency. 3. Private School Documentation: Effective immediately, require written wage documentation from private schools for all Title I-funded employees, with documents retained for audit purposes. 4. Update the written procedures related to federal and state funded payroll charges and provide refresher training for payroll and program staff by December 31, 2025. Responsible Officials - Business Manager – Oversight and monitoring of corrective actions - HR/Payroll Specialist – Implementation of payroll coding and reconciliation procedures - Title I Coordinator – Verification and retention of private school documentation Completion Date All corrective actions will be fully implemented by December 31, 2025. Monitoring and Sustainability The District will conduct quarterly internal reviews of Title I payroll activity, maintaining a monitoring log, requiring time and effort sheets and retaining documentation in the business office. Annual refresher training will be provided to ensure ongoing compliance with federal requirements. Views of Responsible Officials The District concurs that stronger documentation and monitoring are necessary. Program coding is established in the payroll system during employee setup, and controls exist to ensure proper allocation. The purpose of the timeclock system is to log hours. The issue arose due to insufficient secondary review rather than the absence of program coding. Immediate corrective measures have already been taken, and the District is committed to implementing the above actions to ensure full compliance with 2 CFR 200.303 and 2 CFR 200.430(g).
Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will im...
Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will implement a process to ensure that a reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed. Contact person responsible for corrective action: Emily Herbert, Director of Business and Finance Anticipated Completion Date: June 30, 2026
Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and N...
Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and November 30, 2025 Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for verifying program employee listings are complete under Uniform Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Action Taken: The Business Manager will provide semi-annual certification templates to all program directors. The Business Manager and program directors will review staff listings together to ensure all necessary employees are listed. Training on the certification process will be provided to all directors of federally funded programs. All federally funded salaried employees are required to complete certifications twice each year. The first submission is due to the Business Manager by January 15, and the second is due by July 15. The Business Manager will verify and maintain all certification records. Responsible Person and Anticipated Completion Date: Business Manager, November 2025 If the Michigan Department of Education has questions regarding this plan, please call CJ Van Wieren at (231) 893-1005.
Improper Time & Effort Reporting Condition: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activitie...
Improper Time & Effort Reporting Condition: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activities), this often necessitates the use of personnel activity reports or similar timekeeping documents to accurately allocate salaries and wages. During the audit, we found that proper personnel activity reports were not being maintained for multiple cost objective employees charged to Title IV and to the Special Education Cluster. While we were able to support that the amounts charged to the grants were reasonable, through review of the employee's Outlook calendars, daily schedules, etc., the documentation required by federal guidance was not available. We recommend that management provide training to all multiple cost objective employees on how to properly document their time and then to Implement oversite procedures requiring that those personnel activity reports be submitted to management for review on a monthly basis. Corrective Action: The District has begun training all staff and grant Directors on the proper documentation required to properly support the time and effort employees spend on various grants. In addition, the Grant Director will begin reviewing this documentation on a periodic basis, to ensure complete compliance. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.
Admin Offices 4301 S Cowan Rd Muncie, IN 47302 765-747-5222 office CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2025 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Progr...
Admin Offices 4301 S Cowan Rd Muncie, IN 47302 765-747-5222 office CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2025 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Context: During testing of allowable activities and costs, it was observed that the School Corporation allocated payroll and benefit expenses to the school lunch fund for the employee overseeing the food service management company. Five payroll transactions totaling $5,476 were selected for testing. For each transaction tested, the School Corporation allocated 18% of the employee’s time to the school lunch fund. Although the employee completed an annual self-certification estimating time spent on food service duties, there was no detailed time and effort log to support actual hours worked. Additionally, no internal control existed to provide a documented secondary review of the self-certification for accuracy and completeness. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will no longer charge any payroll and benefit expenses to the school lunch fund. Anticipated Completion Date: July 1, 2025.
View Audit 373490 Questioned Costs: $1
2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been de...
2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines da...
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.
View Audit 370942 Questioned Costs: $1
Finding 2024-053 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll Documentation) Auditor's Summary of the Finding The auditors concluded that the Nevada Division of Emergency Management (DEM) did not maintain sufficient documentation to support the allocation of employe...
Finding 2024-053 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll Documentation) Auditor's Summary of the Finding The auditors concluded that the Nevada Division of Emergency Management (DEM) did not maintain sufficient documentation to support the allocation of employee salaries and wages charged to the Homeland Security Grant Program. Specifically, documentation supporting payroll distributions was not available for all sampled payroll transactions, resulting in questioned payroll costs. The auditors recommended that DEM strengthen internal controls to ensure documentation supporting the distribution of employee salaries and wages is maintained. OEM Response The Nevada Office of Emergency Management (OEM), formerly the Nevada Division of Emergency Management (DEM) during the FY 2024 audit period, agrees that documentation supporting payroll distributions should be consistently maintained and readily available to demonstrate compliance with applicable federal requirements. During the audit period, DEM maintained internal controls over payroll administration that included supervisory approval of employee payroll, salary certifications validating payroll distributions, and fiscal review of personnel costs charged to Homeland Security Grant Program awards. Salary certifications were used to verify that payroll distributions accurately reflected work performed and supported the allocation of personnel costs to applicable federal awards. The audit identified that salary certifications and supporting documentation for certain sampled payroll transactions were not available during the audit. While OEM believes these documentation deficiencies did not indicate that payroll costs were improperly charged to the grant, the absence of complete documentation for the sampled transactions limited DEM's ability to demonstrate compliance with the documentation requirements of 2 C.F.R. § 200.430. Corrective Action Planned OEM has revised its Internal Control Manual to strengthen documentation and retention requirements for personnel costs charged to federal awards. The revised Personnel and Payroll section formally requires salary certifications, payroll documentation, maintenance of personnel records, and grant-specific payroll documentation. The Grant Management section incorporates these documentation requirements into the administration of federal awards to ensure supporting records are retained as part of the official grant file. OEM will continue to use salary certifications to validate payroll distributions and will implement additional management oversight to ensure certifications and supporting payroll documentation are consistently completed, retained, and readily available for monitoring and audit purposes. These enhancements reinforce existing payroll controls while improving documentation retention and demonstrating compliance with 2 C.F.R. § 200.430. Responsible Official(s) • Jared Franco, Chief Fiscal Officer • Judith Lyman, Budget Officer Anticipated Completion Date Implemented through the 2026 Internal Control Manual. Revised documentation and record retention procedures are currently in effect and will be applied to all active and future Homeland Security Grant Program awards.
Planned Corrective Action: Valley Health Associates will implement a consistent review process per pay period to ensure payroll is allocated accurately to each program to the best ability possible and take quick action to fix any errors or adjustments.
Planned Corrective Action: Valley Health Associates will implement a consistent review process per pay period to ensure payroll is allocated accurately to each program to the best ability possible and take quick action to fix any errors or adjustments.
PLC transitioned to a new HRIS software in mid-2024, which disrupted our usual process for documenting approval of employee salary/pay rates. PLC’s HR department has incorporated a new procedure for documenting personnel actions that is compatible with our HRIS software.
PLC transitioned to a new HRIS software in mid-2024, which disrupted our usual process for documenting approval of employee salary/pay rates. PLC’s HR department has incorporated a new procedure for documenting personnel actions that is compatible with our HRIS software.
Twin Oaks employs most of their 700 or so employees in residential programs where they work for one program on a set schedule. Twin Oaks is working with Paylocity to create the best solution for those employees that work for different programs or that have multiple programs at their location. The pr...
Twin Oaks employs most of their 700 or so employees in residential programs where they work for one program on a set schedule. Twin Oaks is working with Paylocity to create the best solution for those employees that work for different programs or that have multiple programs at their location. The programs specifically identified with this finding have been eliminated except for the TOCS programs and that is where we are specifically working on the best solution with Paylocity. Benjie Read and Candy Gregory will be responsible for correcting this with Paylocity by October 31, 2026.
During fiscal year 2026, the Coalition engaged an outsourced accounting firm to assist with grant compliance and financial reporting. The Coalition has implemented procedures requiring employees whose activities benefit multiple funding sources to document actual time and effort by program or activi...
During fiscal year 2026, the Coalition engaged an outsourced accounting firm to assist with grant compliance and financial reporting. The Coalition has implemented procedures requiring employees whose activities benefit multiple funding sources to document actual time and effort by program or activity. Payroll allocations will be reviewed periodically and adjusted as necessary to reflect actual work performed. Management and the outsourced accounting team will maintain supporting documentation for payroll allocations and monitor compliance with Uniform Guidance requirements.
IIW acknowledges the finding regarding the allocation of payroll expenses to federal awards during the period July 2023 through October 2023. FY2024 was a significant transition period for IIW. New payroll and financial systems were implemented during the transition period from June 2023 through Jan...
IIW acknowledges the finding regarding the allocation of payroll expenses to federal awards during the period July 2023 through October 2023. FY2024 was a significant transition period for IIW. New payroll and financial systems were implemented during the transition period from June 2023 through January 2024, and management implemented significant corrective actions related to payroll allocation beginning in November 2023. These corrective actions included transitioning away from the prior budget-based payroll allocation methodology, strengthening timekeeping and payroll processes, implementing procedures designed to document actual employee activities, and enhancing supervisory review of payroll allocations. Although aspects of the prior-year condition affected the July through October 2023 period of FY2024, significant corrective measures were implemented during FY2024 beginning in November 2023. IIW continued strengthening these processes throughout FY2024. Corrective Actions Implemented and Ongoing • Implement and maintain written payroll allocation policies and procedures. • Utilize systematic timekeeping practices designed to document actual employee activities. • Allocate payroll costs based on actual work performed and appropriate supporting documentation. • Maintain supervisory review and approval procedures over employee time reporting and payroll allocations. • Maintain appropriate levels of management review and oversight to provide checks and balances over payroll reporting and allocation. • Periodically review payroll allocations for consistency with actual employee activity and make adjustments when necessary. Contact Persons Responsible for Corrective Action Paul F. Trebian, President & CEO Estela Vazquez-Ornelas, Vice President Anticipated Completion Date Significant corrective actions were implemented beginning in November 2023 and continue to be monitored and enhanced as necessary to ensure compliance with federal award requirements.
Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management ackn...
Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management acknowledges the requirement that personnel costs charged to HUD awards (e.g., CDBG, HOME, CoC) must be supported by records that accurately reflect work performed on eligible program activities. Corrective Actions Implemented: The Organization has strengthened internal controls over payroll allocation for HUD-funded programs by implementing a formal monthly review and reconciliation process based on after-the-fact determinations of actual activity. Under this enhanced process: • Payroll costs charged to HUD awards are reviewed monthly and supported by documentation that reflects actual time and effort by eligible activity and funding source. • Payroll distribution reports are evaluated for accuracy, allowability, and alignment with HUD-eligible program activities. • Allocated payroll costs are compared to actual program delivery (e.g., beneficiary services, project activities, administrative vs. program caps, where applicable). • Timely cost adjustments are recorded, as necessary, to ensure payroll charges are properly aligned with work performed and eligible cost objectives. • All adjustments are documented, reviewed, and approved by appropriate supervisory and finance personnel. Expected Outcome: Management believes these corrective actions will ensure that payroll costs charged to HUD-funded programs are accurate, allowable, properly documented, and aligned with eligible program activities, and fully compliant with Uniform Guidance and HUD requirements. These enhancements will strengthen internal controls, improve reporting reliability (including IDIS/financial reporting where applicable), and reduce the risk of noncompliance in future monitoring or audit reviews.
Finding Number 2024-024 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-024 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
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