2023-005 – Department of the Interior Federal Program Name: Natural Resource Stewardship - Pass-Through Agency: N/A Assistance Listing Number: 15.944 Federal Award Identification Year: 2023 Award Period: 10/01/2022 – 09/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.414(c) – Federal awards recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support the indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation Condition: For all invoices submitted to the grantor including those that included indirect cost rate calculations, there was no documented review and approval of the submission by management. Condition: Known: $94,287 Likely: $94,287 Context: Internal controls need to be formally documented as well as have support and authorization. With no authorization or proof that the internal control was completed, we cannot rely on the controls. Effect: Not having internal controls formalized and documented can lead to higher risk of noncompliance and misreporting. Cause: Internal controls are not formalized or documented Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed above. Management’s Views: See separate corrective action plan.
Finding No.: 2023-010 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Aid Portion Federal Award No.: COVID-19 P425E204126 AL Sub-Program: 84.425F HEERF - Institutional Portion Federal Award No.: COVID-19 P425F202732 AL Sub-Program: 84.425L HEERF - Minority Serving Institution Federal Award No.: COVID-19 P425L200219 Area: Cash Management Questioned Costs: Undeterminable Criteria: 2 CFR section 200.302(b)(6) states that the recipient must establish written procedures to implement the requirements of 2 CFR section 200.305. Specifically, 2 CFR section 200.305(b) states that for recipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Furthermore, per OMB Compliance Supplement May 2023, Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Condition: The College does not have written procedures to implement the requirements set in the criteria above. Furthermore, monitoring of actual disbursements of the following drawdowns during the year was not performed: Cause: The College lacks written policies and procedures over cash management, including monitoring of actual disbursements of drawdowns. Effect: The College is in noncompliance with applicable cash management requirements. Questioned costs, if any, that may result from non-monitoring of actual disbursements are not determinable. Identification as a Repeat Finding: 2022-021 Recommendation: College management should establish written policies and procedures over cash management, including monitoring of actual disbursements of drawdowns. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.
FEDERAL PROGRAM ALL FEDERAL PROGRAMS ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS AWARD NUMBERS ALL AWARDS COMPLIANCE REQUIREMENT ACTIVITIES ALLOWED OR UNALLOWED TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA Uniform Guidance at 2 CFR 200 §200.302, Financial Management, establishes that: “(a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State's funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. (See § 200.450). (b) The recipient's and subrecipient's financial management system must provide for the following (see §§ 200.334, 200.335, 200.336, and 200.337): (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. (3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. … (6) Written procedures to implement the requirements of § 200.305. (7) Written procedures for determining the allowability of costs in accordance with subpart E and the terms and conditions of the Federal award.” STATEMENT OF CONDITION As part of our understanding of internal controls and compliance testing regarding activities allowed or unallowed, we obtained a procedures manual. We found the following deficiencies: • The Center provided written internal control procedures over federal funds management. We observed that the policy didn’t include any detail of procedures, just a general requirement. In addition, the policy does not identify the personnel responsible for the processes to establish segregation of duties. • We selected a sample of 10 (number of disbursements selected) federal funds disbursed and noted that invoices are not marked as they are paid. • From the sample of federal funds disbursed, no evidence was found of approval or verification of allowability of the disbursement, proper segregation of duties, or accountability. • The Center lacks an adequate process to provide regular training to staff on Generally Accepted Government Auditing Standards, general documentation, acquisitions levels, formal agreements with vendors, vendor selections guidelines and best practices, required documentation regarding grant requirements and other internal best practices. QUESTIONED COSTS No questioned costs identified. PERSPECTIVE INFORMATION This is a systematic deficiency. After conducting personnel interviews, we were able to identify procedures for validating the payments. The person told us that after a need to purchase goods or services is identified by the centers, the entity Administrator requests authorization from the President. The President validates with the external accounting firm that the expense category is included in the approved budget and that funds are available before approving the payment. Procedures and internal controls manuals should provide for and ensure the segregation of duties. STATEMENT OF CAUSE The Center didn't have adequate internal controls in place, or documentation that presented adequate segregation of duties and compliance with applicable laws and regulations. In addition, no internal controls were documented that supported proper accountability of funds. POSSIBLE ASSERTED EFFECT The Center could incur in unallowable costs or activities and not be able to prevent or detect a transaction that doesn't comply with the Federal regulation. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend that management establish an adequate internal controls process that identifies documentation, personnel responsible and authorizations. In addition, we recommend management to update established written procedures and internal controls manuals to provide and document the segregation of duties related to the activities allowed or unallowed compliance requirement.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs September 30, 2023 Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements is in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The close-out process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, accounts payable, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to properly present the financial statements and disclosures of the Authority as of September 30, 2023. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, IRS Form 990 filings, state filings, etc.) Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425). The SEFA may exclude pertinent information required by the Uniform Guidance. The systemic cause appears to be the untimely resignation of key personnel, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Context: Review of internal control structure of the Authority’s in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP and GAS. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] (Continued) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. When applicable to a single audit, the auditor must report as audit findings, significant deficiencies and material weaknesses in internal control over major programs (2 CFR §200.516(a)). In addition, Government Auditing Standards require auditors to report as findings significant deficiencies and material weaknesses in internal control over financial reporting identified during the audit. Effect: The risk exists that financial statements, the SEFA and other accounts and disclosures (including cash, fixed assets, grant-related receivables, deferred revenue, allocations, and cash) may not be recorded properly during the reporting period (interim and annually) and that errors may not be prevented, or detected and corrected, on a timely basis. This condition may also make it difficult for the Authority to prepare accurate and timely external reports required by various regulatory agencies and funding sources (for example, the SF-425, where applicable) and may increase the risk of noncompliance with grant and contract requirements. Cause: The cause appears to be, which may include one or more of the following: untimely resignation or turnover of key personnel; limited availability of personnel with sufficient training and experience in nonprofit and grant accounting and related compliance reporting; changes in systems and/or processes that were not accompanied by commensurate controls; and policies and procedures not being followed consistently throughout the year. Recommendation: We recommend that the Authority strengthen internal controls over the month-end and year-end financial reporting close process and grant/contract closeout activities. At a minimum, the Authority should: 1. Assign qualified personnel (internal staff and/or qualified third-party support under appropriate management oversight) to perform and document key monthly close procedures, including timely bank reconciliations, review of receivables and deferred revenue, review of grant activity, and review/approval of journal entries. 2. Implement and document supervisory review controls over the preparation of financial statements, related disclosures, and the SEFA, including review of significant estimates, allocations, and reconciliations. 3. Establish a compliance calendar and documented procedures to support timely, accurate external regulatory reporting, including IRS Forms 941, IRS Form 990, Form 5500, applicable state filings, and grantor reports such as the SF-425 and other State department filings, where applicable. 4. Provide targeted training and/or hire/retain personnel with appropriate nonprofit and grant accounting experience, including Uniform Guidance reporting requirements, commensurate with the Authority’s size and complexity. (Continued) 5. Update and consistently follow written accounting policies and procedures, including documented reviews and retention of support for key controls. Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. All enhancements will be implemented by September 30, 2026.
Special Tests and Provisions – ERA Funds Reallocation Federal Agency: U.S. Department of the Treasury Federal Program Title: Emergency Rental Assistance Program ALN: 21.023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 1505-0270 – 2021 May 5, 2021 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR §200.302, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. Per 2 CFR §200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Treasury’s ERA2 Reallocation Guidance Updated November 15, 2022, the ERA2 statute requires Treasury to identify funds for reallocation from amounts allocated to eligible Grantees, but not yet paid out to them. Specifically, the statute provides that beginning on March 31, 2022, Treasury must “reallocate funds allocated to eligible grantees … but not yet paid,” according to a procedure established by Treasury. Condition: Audit procedures included a review of the ERA2 Quarter 3 2022 (July-September) and ERA2 Quarter 4 2022 (October-December) Compliance Reports. We noted that $6,777,186 was double counted on the ‘Cumulative Amount of Award Obligated as of the end of the Reporting Period’ amount in the ERA2 Quarter 4 2022 Compliance Report. Questioned costs: None. Context: See "Condition" Cause: Obligated amounts were duplicated when preparing the supporting worksheets due to management oversight. Effect: Inaccurate supporting data when calculating reallocation expenditure ratios may result in an incorrect amount of excess funds subject to recapture by Treasury. Repeat finding: 2022-025 Recommendation: We recommend management enhance its internal controls over the review of supporting reallocation expenditure ratio calculations. Views of responsible officials: Management agrees with the finding and recommendation
Health Center Infrastructure Support Financial Reporting Federal Agency: Department of Health and Human Services Program: Health Center Infrastructure Support Assistance Listing #: 93.526 Criteria In accordance with OMB Uniform Guidance 2 CFR 200.302(2), the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition The Health Center Infrastructure Support award requires recipients to submit a Federal Financial Report (FFR) on an annual basis. Sunset Park submitted the FFRs due in 2023 and 2024 (for expenses incurred in 2022 and 2023, respectively) in a timely manner, however, the financial information included on the FFRs was reported on a cash basis instead of the accrual basis indicated by Sunset Park on the FFRs. Cause Sunset Park did not select the appropriate basis of accounting on the FFRs that correlated to the financial information being reported. Effect The FFRs submitted for the 2022 and 2023 budget periods underreported cumulative federal expenditures incurred under the program by $1,049,618, which represents the difference between expenditures incurred through the end of the 2023 budget period and cash receipts as of that same date. The Schedule of Expenditures of Federal Awards in both years, however, accurately reported the accrual basis expenditures. Questioned Costs There are no questioned costs associated with this finding. Recommendation Sunset Park should contact the Federal awarding agency to determine appropriate action to correct the previously submitted FFRs. Sunset Park should also enhance its control procedures to ensure that FFRs submitted are reconciled to the underlying accounting records to ensure accurate, current, and complete disclosure.
: Per 2 CFR 200.302, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Special Tests and Provisions – ERA Funds Reallocation Federal Agency: U.S. Department of the Treasury Federal Program Title: Emergency Rental Assistance Program ALN: 21.023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 1505-0270 – 2021 May 5, 2021 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR §200.302, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. Per 2 CFR §200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Treasury’s ERA2 Reallocation Guidance Updated November 15, 2022, the ERA2 statute requires Treasury to identify funds for reallocation from amounts allocated to eligible Grantees, but not yet paid out to them. Specifically, the statute provides that beginning on March 31, 2022, Treasury must “reallocate funds allocated to eligible grantees … but not yet paid,” according to a procedure established by Treasury. Condition: Audit procedures included a review of the ERA2 Quarter 3 2022 (July-September) and ERA2 Quarter 4 2022 (October-December) Compliance Reports. We noted that $6,777,186 was double counted on the ‘Cumulative Amount of Award Obligated as of the end of the Reporting Period’ amount in the ERA2 Quarter 4 2022 Compliance Report. Questioned costs: None. Context: See "Condition" Cause: Obligated amounts were duplicated when preparing the supporting worksheets due to management oversight. Effect: Inaccurate supporting data when calculating reallocation expenditure ratios may result in an incorrect amount of excess funds subject to recapture by Treasury. Repeat finding: 2022-025 Recommendation: We recommend management enhance its internal controls over the review of supporting reallocation expenditure ratio calculations. Views of responsible officials: Management agrees with the finding and recommendation
Health Center Infrastructure Support Financial Reporting Federal Agency: Department of Health and Human Services Program: Health Center Infrastructure Support Assistance Listing #: 93.526 Criteria In accordance with OMB Uniform Guidance 2 CFR 200.302(2), the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition The Health Center Infrastructure Support award requires recipients to submit a Federal Financial Report (FFR) on an annual basis. Sunset Park submitted the FFRs due in 2023 and 2024 (for expenses incurred in 2022 and 2023, respectively) in a timely manner, however, the financial information included on the FFRs was reported on a cash basis instead of the accrual basis indicated by Sunset Park on the FFRs. Cause Sunset Park did not select the appropriate basis of accounting on the FFRs that correlated to the financial information being reported. Effect The FFRs submitted for the 2022 and 2023 budget periods underreported cumulative federal expenditures incurred under the program by $1,049,618, which represents the difference between expenditures incurred through the end of the 2023 budget period and cash receipts as of that same date. The Schedule of Expenditures of Federal Awards in both years, however, accurately reported the accrual basis expenditures. Questioned Costs There are no questioned costs associated with this finding. Recommendation Sunset Park should contact the Federal awarding agency to determine appropriate action to correct the previously submitted FFRs. Sunset Park should also enhance its control procedures to ensure that FFRs submitted are reconciled to the underlying accounting records to ensure accurate, current, and complete disclosure.
: Per 2 CFR 200.302, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
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.
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.