Corrective Action Plans

THE COALITION WILL MAINTAIN A CENTRALIZED GRANT REGISTER IDENTIFYING EACH AWARD NUMBER, PROJECT CODE, BEGINNING DATE, ENDING DATE, AND APPROVED PERIOD OF PERFORMANCE. FINANCE WILL USE THE REGISTER DURING MONTHLY CLOSE AND GRANT REVIEW TO VERIFY THAT PAYROLL AND NON-PAYROLL EXPENDITURES ARE CHARGED TO THE CORRECT ACTIVE GRANT/PROJECT. BEFORE AND AFTER AN AWARD END DATE, FINANCE WILL REVIEW PROJECT ACTIVITY FOR COSTS POSTED OUTSIDE THE APPROVED PERIOD, CONFIRM WHETHER ANY PRE-AWARD OR CLOSEOUT COST IS AUTHORIZED, AND RECLASSIFY MISCODED TRANSACTIONS BEFORE GRANT REPORTING IS FINALIZED. NEW AWARD/PROJECT CODES WILL BE ESTABLISHED AND COMMUNICATED BEFORE COSTS ARE CHARGED TO A SUCCESSOR AWARD. IN ADDITION, AFTER THE MONTHLY CLOSE PROCESS IS COMPLETE, FINANCE WILL DISTRIBUTE GRANT STATEMENTS TO ADMINISTRATION TO REVIEW EXPENDITURES AND REMAINING GRANT BALANCES FOR REASONABLENESS. THIS PROVIDES AN ADDITIONAL LAYER OF OVERSIGHT TO VERIFY THAT GRANT-RELATED EXPENSES HAVE BEEN RECORDED ACCURATELY.

THE COALITION WILL REQUIRE DOCUMENTED REVIEW AND APPROVAL OF EMPLOYEE TIME FOR EVERY PAYROLL PERIOD AND WILL RETAIN PAYROLL AND TIMEKEEPING RECORDS IN AN AUDIT-ACCESSIBLE LOCATION. BEFORE PAYROLL IS PROCESSED, DESIGNATED MANAGEMENT WILL REVIEW TIME ENTRIES FOR COMPLETENESS, FUNDING ALLOCATION, LEAVE, AND APPROVAL STATUS. THE PAYROLL FILE RETAINED FOR EACH PERIOD WILL INCLUDE THE APPROVED TIME RECORD, PAYROLL REGISTER, ALLOCATION DETAIL, AND EVIDENCE OF PREPARER/REVIEWER APPROVAL. WHEN TIMEKEEPING OR PAYROLL SYSTEMS CHANGE, THE COALITION WILL EXPORT AND PRESERVE HISTORICAL REPORTS AND APPROVAL RECORDS FOR THE APPLICABLE RECORD-RETENTION PERIOD BEFORE ACCESS TO THE PRIOR SYSTEM ENDS.

THE COALITION WILL FORMALIZE AND RETAIN A DOCUMENTED ALLOCATION CONTROL PROCESS FOR EXPENSES CHARGED TO FEDERAL PROGRAMS. ON A MONTHLY BASIS, FINANCE WILL RECONCILE PAYROLL REPORTS FROM GUSTO TO THE GENERAL LEDGER TO ENSURE PAYROLL ENTRIES POSTED TO THE GL AGREE TO THE PAYROLL REGISTER FOR THE APPLICABLE PAY PERIOD. THESE RECONCILED PAYROLL ENTRIES WILL SERVE AS THE BASIS FOR ALL PAYROLL ALLOCATIONS. FOR PAYROLL ALLOCATIONS, THE PAYROLL REGISTER WILL SERVE AS THE SOURCE DOCUMENT AND WILL BE RECONCILED TO THE ALLOCATION WORKSHEET AND THE CORRESPONDING JOURNAL ENTRY POSTED TO THE GENERAL LEDGER. THE RECONCILIATION WILL IDENTIFY THE PAYROLL PERIOD, EMPLOYEE, SOURCE PAYROLL AMOUNT, ALLOCATION METHODOLOGY, FUNDING SOURCE OR PROJECT, AND RESULTING JOURNAL ENTRY. A PREPARER AND AN INDEPENDENT REVIEWER WILL DOCUMENT COMPLETION AND APPROVAL, AND THE SUPPORTING DOCUMENTATION WILL BE RETAINED WITH THE JOURNAL ENTRY TO ENSURE ALLOCATED AMOUNTS CAN BE TRACED BACK TO THE ORIGINATING PAYROLL RECORDS. IN ADDITION, FINANCE WILL RECONCILE ON A MONTHLY BASIS, THE PAYROLL REPORTS FROM GUSTO TO THE GENERAL LEDGER, ENSURING THAT THE PAYROLL ENTRIES POSTED TO THE GL TIE DIRECTLY BACK TO THE PR REGISTER FOR THAT TIME PERIOD. THESE PAYROLL ENTRIES (FROM GUSTO) ARE THEN WHAT IS USED TO CREATE THE ALLOCATIONS. ANY UNEXPLAINED VARIANCE WILL BE RESOLVED BEFORE THE JOURNAL ENTRY IS FINALIZED

THE IDAHO COALITION WILL IMPLEMENT STRENGTHENED INTERNAL CONTROLS OVER THE ALLOCATION OF NON-PAYROLL EXPENSES TO FEDERAL PROGRAMS, CONSISTENT WITH 2 C.F.R. PART 200 AND THE DOJ GRANTS FINANCIAL GUIDE. SPECIFICALLY, THE ORGANIZATION WILL: 1. DOCUMENT ALLOCATION METHODOLOGY: ESTABLISH AND MAINTAIN WRITTEN PROCEDURES THAT CLEARLY DESCRIBE THE ALLOCATION METHODOLOGY FOR NON-PAYROLL EXPENSES, ENSURING COSTS ARE 1402 W GROVE STREET BOISE, IDAHO 83702 WWW.IDAHOCOALITION.ORG ALLOWABLE, REASONABLE, AND ALLOCABLE TO EACH FEDERAL AWARD. 2. APPROVAL & REVIEW: REQUIRE CONTEMPORANEOUS REVIEW AND APPROVAL OF ALL NON-PAYROLL ALLOCATION JOURNAL ENTRIES BY THE FINANCE STEWARD (OR DESIGNATED FINANCE STAFF) AND THE EXECUTIVE DIRECTOR. 3. SUPPORTING DOCUMENTATION: MAINTAIN SOURCE DOCUMENTATION (E.G., INVOICES, ALLOCATION SCHEDULES, APPROVAL RECORDS) IN THE FINANCIAL SYSTEM TO DEMONSTRATE COMPLIANCE WITH UNIFORM GUIDANCE STANDARDS. 4. QUARTERLY MONITORING: CONDUCT QUARTERLY RECONCILIATIONS OF ALLOCATIONS TO ENSURE COMPLIANCE WITH FEDERAL COST PRINCIPLES. 5. TRAINING: PROVIDE TRAINING TO FINANCE STAFF AND MANAGERS ON ALLOWABLE COST REQUIREMENTS UNDER 2 C.F.R. § 200.403–405 AND OVW/HHS AWARD CONDITIONS TO REINFORCE COMPLIANCE.