Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior pr...
Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of distributing payroll costs using predetermined allocation percentages for employees working across multiple programs did not fully satisfy federal requirements for documenting actual time expended on CDBG-eligible activities. Management notes that the projected questioned costs of $217,355 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City is prepared to work with HUD to determine the appropriate resolution of these questioned costs. The City is implementing the following corrective actions: 1. Actual Time Reporting: Effective immediately, all employees who charge any portion of their time to federal grant programs—including CDBG—are required to document actual hours worked on each program or activity in their timesheets. Time entries must correspond to specific program activities and must be reviewed and certified by the employee's supervisor each pay period. 2. Discontinuation of Fixed Allocation Percentages: The City is eliminating the use of predetermined payroll allocation percentages as the basis for charging personnel costs to federally funded programs. Future payroll charges to federal awards will be based exclusively on actual documented hours, in compliance with 2 CFR 200.430(i). 3. Staff Training: The City will provide mandatory training to all employees who charge time to federal programs, supervisors responsible for timesheet review, and payroll staff. Training will cover the requirements of 2 CFR 200.430, the City's updated time documentation procedures, and the consequences of noncompliance.4. Quarterly Internal Compliance Reviews: Beginning in Q1 of FY 2025-26, the Accounting & Finance Division will conduct quarterly reviews of payroll charges to all federal programs to confirm that expenditures are supported by compliant time records. Results will be reported to the applicable department directors.