Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: The non-Federal entity must: (a) 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: The non-Federal entity must: (a) 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: The non-Federal entity must: (a) 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: The non-Federal entity must: (a) 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): The non-Federal entity must: (a) 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: Various, including AL 93.778 ? Medical Assistance Program ? Allowable Costs/Cost Principles Grant Number & Year: Various, including #2105NE5ADM, FFY 2021 Federal Grantor Agency: U.S. Department of Health and Human Services Criteria: 2 CFR ? 200.403 (January 1, 2022) and 45 CFR ? 75.403 (October 1, 2021) state, in relevant part, the following: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: * * * * (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. * * * * (g) Be adequately documented. 2 CFR ? 200.405(b) (January 1, 2022) and 45 CFR ? 75.405(b) (October 1, 2021) state, in relevant part, the following: All activities which benefit from the non-Federal entity?s indirect (F&A) cost, including unallowable activities and donated services by the non-Federal entity or third parties, will receive an appropriate allocation of indirect costs. 2 CFR ? 200.444(a) (January 1, 2022) and 45 CFR ? 75.444(a) (October 1, 2021) state, in relevant part, the following: For states, local governments, and Indian Tribes, the general costs of government are unallowable ?.Unallowable costs include: (1) Salaries and expenses of the Office of the Governor of a state . . . [.] (2) Salaries and other expenses of a state legislature . . . [.] 2 CFR ? 200, Appendix V, subsection (G)(2), (January 1, 2022) and 45 CFR ? 75, Appendix V, subsection (G)(2), (October 1, 2021) state the following: Internal service funds are dependent upon a reasonable level of working capital reserve to operate from one billing cycle to the next. Charges by an internal service activity to provide for the establishment and maintenance of a reasonable level of working capital reserve, in addition to the full recovery of costs, are allowable. A working capital reserve as part of retained earnings of up to 60 calendar days cash expenses for normal operating purposes is considered reasonable. A working capital reserve exceeding 60 calendar days may be approved by the cognizant agency for indirect costs in exceptional cases. 2 CFR ? 200, Appendix V, subsection (G)(4), (January 1, 2022) and 45 CFR ? 75, Appendix V, subsection (G)(4), (October 1, 2021) state, in relevant part, the following: Billing rates used to charge Federal awards must be based on the estimated costs of providing the services, including an estimate of the allocable central service costs. A comparison of the revenue generated by each billed service (including total revenues whether or not billed or collected) to the actual allowable costs of the service will be made at least annually and an adjustment will be made for the difference between the revenue and the allowable costs. These adjustments will be made through one of the following adjustment methods: (a) a cash refund including earned or imputed interest from the date of transfer and debt interest, if applicable, chargeable in accordance with applicable Federal cognizant agency for indirect costs regulations to the Federal Government for the Federal share of the adjustment, (b) credits to the amounts charged to the individual programs, (c) adjustments to future billing rates, or (d) adjustments to allocated central service costs. A good internal control plan requires: ? Procedures to ensure rate charges are equitable, reflect actual costs incurred, and are reviewed periodically to ensure such charges are appropriate for the services provided. ? Maintenance of adequate documentation to support both rates charged and the approval of those rates. ? Periodic review of internal service fund balances to ensure revenues are not in excess of expenses. ? Internal service rates that are published and available for State agency review and applied consistently for all State agencies. Condition: The Agency did not have adequate documentation to support the allocation of security costs in developing building rental rates. Additionally, the Agency?s Material Division did not maintain adequate documentation to support that charges were reasonable, equitable, and consistently applied. A similar finding was noted in prior audits since 2015. Lastly, the Accounting Internal Service Fund balance was greater than 60 calendar days for cash expenses for normal operations incurred. A similar finding was noted in the prior audit. Repeat Finding: 2021-024 Questioned Costs: Unknown Statistical Sample: No Context: We noted the following: Building Division The rental rate charged to agencies for building space includes an allocation for indirect costs for administration, grounds keeping, security, and energy management. We noted that neither the State Capitol nor the Governor?s residence were allocated any costs for security, even though there is security at both locations. Because these locations were not allocated any security costs, Federal programs could be overcharged. Additionally, security costs to the State Capitol and the Governor?s residence are general costs of government and, therefore, not allowable. The fiscal year 2022 indirect allocations for security totaled $884,797. Material Division We tested three Print Shop billings and noted the following: ? In prior audits, we noted that 24 Print Shop rates were based on calculations from fiscal year 2008, and 3 other Print Shop rates were based on calculations from fiscal year 2011. The Print Shop increased all the rates by 10% in fiscal year 2019, then increased the rates by an additional 5% in fiscal year 2020. In 2022, the rates were decreased by 5%. No support was provided to show that the current rates are reasonable. ? The Agency?s published markup price for special purchases, paper costs, plate material, special order supplies, and colored ink was 35%. The Agency did not have adequate documentation to support the reasonableness of the markup percentage rate. Receipts from sales of print shop services during the fiscal year ended June 30, 2022, totaled $2,835,540. Accounting Division Per the Agency?s calculation, as of June 30, 2021, the Accounting Services Internal Service Fund Balance for allowable costs was $4.528 million; however, the allowable reserve was only $1.007 million, a difference of $3.521 million, more than triple the allowable reserve. The Agency has not completed its calculation for June 30, 2022. The Auditor of Public Accounts (APA) estimate of the fund balance, per review of the accounting system, as of June 30, 2022, was $4.388 million, and the APA estimate of the allowable reserve was $1.007 million, a difference of $3.381 million. Therefore, the Agency appears to be charging too much for services. Cause: Inadequate procedures. Effect: When security costs are not allocated to all buildings in an equitable manner, Federal programs will not be charged in accordance with Federal cost principles. Additionally, without adequate controls and procedures to ensure rates are equitable and based on actual costs, there is an increased risk that Federal programs will be overcharged for services, and the Agency?s internal service funds will exceed the allowable threshold per Federal regulations. Recommendation: We recommend the Agency review its allocation of security costs to ensure that such costs are allocated in an equitable manner to all activities that benefit from the services. Additionally, we recommend the Agency maintain adequate documentation to support charges and ensure rates are equitable and reflect the actual costs incurred for services. Lastly, we recommend the Agency implement procedures to ensure fund balances do not exceed the allowable threshold. Management Response: The Building and Grounds security allocation is based on a management business decision. The Print Shop lacked the data needed to substantiate current rates at the individual service line level. In response to the prior year finding, the Print Shop purchased a Cost Rate Advisor license to support future rate setting methodology at the individual service line level. The Print Shop expects to finalize its analysis by July 2023. State Accounting Rates were reduced by $450,000 in fiscal year 2021, and from that level reduced another $132,000 in fiscal year?s 2022 and 2023 (current biennium). Further offsets of $700,000 are planned for each year of the coming biennium, and planned expenditures will exceed billed revenues by $1.7 million to bring the cash balance to within a 60-day operating level by June 2025.
Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Grant Number & Year: NE-2019-013-00, FFY 2017 Federal Grantor Agency: U.S. Department of Transportation Criteria: Per 2 CFR ? 1201.1 (January 1, 2022), the U.S. Department of Transportation adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at Title 2 CFR part 200. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. A good internal control plan requires procedures to be in place to ensure compliance with Federal and State requirements. 2 CFR ? 200.332(d) (January 1, 2022) requires the pass-through entity to do the following: Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. 2 CFR ? 200.430(i)(1) (January 1, 2022) states the following, in relevant part: 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 control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; * * * * (vii) 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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards . . . [.] Per 2 CFR ? 200.405(a) (January 1, 2022), ?A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Condition: The Agency lacked adequate documentation to support that payments were for allowable activities and in accordance with Federal cost principles. A similar finding was noted in the prior audit. Repeat Finding: 2021-065 Questioned Costs: $64,704 known Statistical Sample: No Context: We tested 25 payments to 22 subrecipients and three vendors. The Agency performed financial desk reviews for subrecipients; however, the reviews tested were not adequate. When desk reviews were not adequate, we provided the Agency with the opportunity to obtain additional support from the subrecipient; however, adequate support was not obtained. We noted the following: ? For nine subrecipients tested, documentation was not adequate to support that personnel charges were allowable and in accordance with Federal cost principles. The Agency did not have timesheets, time certifications, or other payroll documentation on file for all reimbursement requests. In some cases, payroll documentation was on file, but there was not adequate support to verify that the correct amount was charged to the program, as timesheets were not sufficient to identify time allocated to the program when the employee did not work entirely on the Federal program. In addition, for some subrecipients there was not sufficient documentation to support the benefits reimbursed. ? For one subrecipient tested, fuel costs and maintenance expenses were not adequately supported. The expenses were not supported by invoices. ? For seven subrecipients tested, capital and nonoperating costs were not adequately supported. The Agency did not obtain documentation to support the percentage of nonoperating expenditures allocated to the program. Subrecipients may share building space with other city or county offices and, therefore, may be charged a portion of the rent and utilities. While this is allowable, the Agency must obtain documentation to support that the percent allocated to the transit program is reasonable; however, such supporting documentation was not available. We also noted that one subrecipient was improperly reimbursed for sales taxes. The sample population totaled $15,537,764, which included $12,810,135 paid to 60 subrecipients and $2,727,629 vendor payments. Federal payment errors noted in the sample totaled $24,600. The total Federal sample tested was $353,695. Based on the sample tested, the dollar error rate was 6.96% ($24,600/$353,695), which estimates the potential dollars at risk for fiscal year 2022 to be $1,081,428 (dollar error rate multiplied by population). North Fork Area Transit During the course of our audit, we became aware of potential fraud related to the North Fork Area Transit (NFAT), a subrecipient of the Agency. On December 15, 2022, the Director of NFAT was suspended. A warrant was issued for his arrest the next day, alleging theft of up to $1 million between April and December 2022. From April 1, 2022, through June 30, 2022, the Program reimbursed NFAT a total of $582,587. As a result, we selected the April 2022 reimbursement paid to NFAT in June 2022, totaling $101,519, for additional testing. During that testing we identified $40,104 in questioned costs due to the following: ? For all four non-operating personnel (director and managers), documentation was inadequate to support that personnel charges were allowable and in accordance with Federal cost principles, as the timesheets identified only times in and out and did not specify what work the nonoperating employee was performing for the Federal grant. Questioned costs due to the lack of support for nonoperating personnel totaled $24,104. ? A $20,000 payment for vehicle insurance was reported; however, there was no documentation to support how the amount was determined or why it was reasonable. Furthermore, the $20,000 paid was inconsistent with past vehicle insurance payments. We observed a check in March 2022 for $600 with the description that it was for March bus insurance, and previous testing identified $600 bus insurance checks in August 2020 and August 2021. As a result, we question the Federal share of $16,000. ? We also noted inconsistencies in supporting documentation for operating personnel (drivers and dispatchers). Variances were noted between timesheet hours and the payroll register. Due to the NFAT concerns, the APA has now commenced a thorough review of this entire matter, which will be reported separately at a later date. Cause: Procedures were not adequate to ensure that costs were in accordance with Federal requirements. Effect: Increased risk for errors or misuse of funds. Recommendation: We recommend the Agency strengthen subrecipient monitoring procedures. We further recommend the Agency improve procedures to ensure expenditures are allowable and in accordance with Federal regulations. Management Response: The NDOT Local Assistance Division has increased transit staff by 1.5 FTEs for a total of 3.5 FTEs dedicated to reviewing monthly invoices. NDOT continues to engage and educate transit recipients. In late 2022, the North Fork Area Transit (NFAT) Board began an internal review process which revealed an inappropriate use of funds and authorities were notified. In December 2022, the NFAT Board engaged NDOT and requested assistance from the Mobility Management Team following the allegation. The Mobility Management Team is assisting the NFAT Board in managing operations, review of existing reporting and financial policies, and review and update of step-by-step checks and balances process. NDOT is financially supporting the Mobility Management Team in an effort to support and resume services at NFAT.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558) Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Cause: Limitation of current system being utilized to allocate payroll costs. Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time. Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time. Views of Responsible Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.