Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Identification: 2 CFR 200.302 Financial Management; 93.498 United States Department of Health and Human Services, Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution (ARPA); Material weaknesses/Activities Allowed or Unallowed, Allowable Cost/Cost Principle and Reporting Compliance Requirements There was inadequate internal controls in place over financial reporting related to revenue recognition and reconciling general ledger balances to supporting documentation which caused inadequate controls over compliance related to federal programs. See Financial Statement Findings 2023-001, 2023-002, and 2023-003 for a description of these deficiencies, including the views of responsible officials.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Indirect Costs) Repeat Finding: No Condition: The Organization was unable to provide applicable indirect costs rationale documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles. Management was not able to provide the approved indirect rate for the various locations to support the actual indirect cost rate charged. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Cause: The Organization did not have adequate controls over the rationale of indirect cost process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Indirect costs were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Questioned Costs: Unknown. Recommendation: We recommend the Organization establish and implement controls to properly document the indirect costs rationale and approved rate determination to charge to the grant.
Finding Number: 2023-007. Criteria or specific requirement: Adequate financial records should be maintained in accordance with 2 CFR 200.302(b)(3). Condition: The District did not maintain adequate financial records in accordance with 2 CFR 200.302(b)(3). Context: Grant expenditures were coded to the incorrect general ledger accounts. Effect: Due to grant expenditures being coded to the incorrect general ledger accounts, adequate financial records were not maintained in accordance with 2 CFR 200.302(b)(3). Cause: Grant expenditures were coded to the incorrect general ledger accounts. This resulted in inadequate financial records. Recommendation: The District should maintain adequate financial records capable of adequately identifying the source and application of grant funds in accordance wtih 2 CFR 200.302(b)(3). Management's Response: The District will work to maintain records capable of adequately identifying the source and application of grant funds.
Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E – Cost Principals. Condition: Crowhaven Apartments, Inc. did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: Crowhaven Apartments, Inc.’s written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Crowhaven Apartments, Inc. could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Crowhaven Apartments, Inc. draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and are in process of developing and implementing the appropriate policies and procedures.
Criteria: 2 CFR section 200.302(b)(3-4) states “The financial management system of each non-Federal entity must provide for the following… (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes.” Condition: During our audit we noted cases where cumulative expenditures claimed for ESSER II and ESSER III did not agree to the general ledger. Many journal entries were used to move expenditures to/from applicable grants, but they were not always properly reported on the grant expenditure reports. Context: We noted numerous immaterial discrepancies in reporting compared to actual general ledger information from the District. We consider this to be a systemic problem. None of the amounts were material to the program and extrapolation wasn’t practical because of the nature of discrepancies it was difficult to quantify them against all grant expenditures.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for costs that were already previously claimed for reimbursement in the prior year. However, the District was able to correct this error by reclassifying other eligible and allowable costs to the grant. Statement of Cause: Control procedures were not in place to reconcile the accounting records project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: The District had other allowable costs eligible to claim under the grant, therefore no questioned costs were identified. Perspective Information: This appears to be an isolated instance because all other grants received by the District appear to be properly accounted for and utilized the correct project code and source code. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require all grant reports to be reconciled to the internal accounting records prior to report submission. This reconciliation should be presented in a clear and concise manner to enable another party to review and approve before ultimately getting submitted to the grantor. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. Views of Responsible Officials: I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the District spreadsheets will include reviews by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple reviews and the addition of PO number and date of pay request, this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched to the grant funds obtained through reimbursement. The new procedure will begin immediately.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for costs that were already previously claimed for reimbursement in the prior year. However, the District was able to correct this error by reclassifying other eligible and allowable costs to the grant. Statement of Cause: Control procedures were not in place to reconcile the accounting records project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: The District had other allowable costs eligible to claim under the grant, therefore no questioned costs were identified. Perspective Information: This appears to be an isolated instance because all other grants received by the District appear to be properly accounted for and utilized the correct project code and source code. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require all grant reports to be reconciled to the internal accounting records prior to report submission. This reconciliation should be presented in a clear and concise manner to enable another party to review and approve before ultimately getting submitted to the grantor. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. Views of Responsible Officials: I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the District spreadsheets will include reviews by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple reviews and the addition of PO number and date of pay request, this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched to the grant funds obtained through reimbursement. The new procedure will begin immediately.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.