FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and 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. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $5,476 (Known questioned costs) Context: During testing of allowable activities and costs, it was observed that the School Corporation allocated payroll and benefit expenses to the school lunch fund for the employee overseeing the food service management company. Five payroll transactions totaling $5,476 were selected for testing. For each transaction tested, the School Corporation allocated 18% of the employee’s time to the school lunch fund. Although the employee completed an annual self-certification estimating time spent on food service duties, there was no detailed time and effort log to support actual hours worked. Additionally, no internal control existed to provide a documented secondary review of the self-certification for accuracy and completeness. Identification as a repeat finding: This is a repeat finding from the immediately prior audit. The prior finding number was 2024-003. Recommendation: We recommend management ensure that time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
ALN 84.027, 84.173, and 84.424 - Special Education Cluster Grants, and Title IV -Grant # 240450, 250450, 250460, 240750, and 250750 - Grants Ending September 30, 2024 and September 30, 2025 Condition and Criteria: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activities), this often necessitates the use of personnel activity reports or similar timekeeping documents to accurately allocate salaries and wages. During the audit, we found that proper personnel activity reports were not being maintained for multiple cost objective employees charged to Title IV and to the Special Education Cluster. While we were able to support that the amounts charged to the grants were reasonable, through review of the employee’s Outlook calendars, daily schedules, etc., the documentation required by federal guidance was not available. Effect: The District is not consistently maintaining the required time and effort reporting documentation for employees being charged to federal grants as required. Cause: There has been significant turnover in staffing and management at the District, and the requirements regarding time and effort reporting were not understood by the new Grant's Director. Context: The FER and all final trial balances for the fiscal years included in the grant were reviewed and evaluated in total. Only the ESSER I FER included overages over 10%. Questioned Costs: $0 - While we were able to support that the amounts charged to the grants were reasonable, through review of the employee’s Outlook calendars, daily schedules, etc., the documentation required by federal guidance was not available. Auditors' Recommendation: We recommend that management provide training to all multiple cost objective employees on how to properly document their time and then to implement oversite procedures requiring that those personnel activity reports be submitted to management for review on a monthly basis. Views of Responsible Officials and Planned Corrective Actions: The District understands the situation and will ensure that all proper time and effort reporting documentation is maintained moving forward. Please see the attached Corrective Action Plan prepared by the District.
Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and November 30, 2025 Specific Requirement: Allowable Costs/Cost Principles Criteria: Section 200.430 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. Appendix B to 2 CFR, Part 225—Selected Items of Cost indicates that where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Questioned Costs: None. Condition: During our detailed testing of time-and-effort reporting for the Head Start Cluster programs, we noted that semi-annual certifications were prepared to comply with federal time and effort requirements. However, the reports were not timely prepared or timely reviewed by the program supervisors with documented approval. Context: Thirteen employees working in the federal program were eligible for semi-annual certifications because their payroll costs were fully allocated to a single federal program or cost objective. Separate semi-annual certifications were prepared for each six-month period during the fiscal year. While all certifications contained the proper components, including documented supervisor approval, they inadvertently excluded two eligible employees from each report originally. These reports were later re-prepared to include these two employees, however, they were not prepared timely as the forms were completed and certified at least two months after the six-month period ending dates. The sample was not a statistically valid sample. This appears to be an isolated condition. Effect: Failure to timely prepare and review time-and-effort reporting could allow improper payroll expenses to be charged to the School District’s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The School District program personnel inadvertently excluded two employees from the list of 100% eligible Head Start employees who are required to complete semi-annual certifications. Although these reports were later fixed, they were not timely reviewed and approved. As a result, semi-annual certifications were not reviewed and approved for these employees during the required timeframes. Repeat Finding: This is not a repeat finding. Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for verifying program employee listings are complete under Uniform Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Views of Responsible Officials: The School District agrees with this finding.
Assistance Listing, Federal Agency, and Program Name - 84.027, 84.173, Department of Education, Special Education Cluster Federal Award Identification Number and Year - 250450 2425, 250493 2425 Pass through Entity - Michigan Department of Education Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.430, costs charged to federal awards must be allowable, allocable, and reasonable for the performance of the award. Payroll costs must be supported by appropriate documentation and reflect work performed for the federal program. Condition - The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - Within the Special Education Cluster, prior to submission of reimbursement requests, three employee's time was coded to the Special Education Cluster when these employees were not eligible to be covered by the grant funds. Additionally, one employees' time that should have been coded to the grant based on qualifications was not coded to the grant. Cause and Effect - Although identified prior to submission of request for reimbursement from the granting agency, the Agency did not perform a timely reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger, causing expenses for the Special Education Cluster to be misstated on the on the draft SEFA initially provided to the auditors. Recommendation - The Agency should put in place processes to ensure that a timely reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed during reviews of each reimbursement request. Views of Responsible Officials and Corrective Action Plan - The Agency agrees with the recommendations above and will implement a process to ensure that a reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed.
Federal programs Research and Development Cluster – National Institutes of Health – Drug Abuse and Addiction Research Programs AL #: 93.279 Award Year: 2024/2025 Type of finding Significant Deficiency and Noncompliance Compliance requirement Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Under 2 CFR section 200.430(i), costs of compensation for personal services are allowable to the extent the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policies and practices, follows an appointment made in accordance with non-federal entities rules and written policies, and is determined and supported as provided in 2 CFR section 200.430(i), including that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition We noted one out of forty judgmentally selected payroll transactions included cost for an employee that did not relate to services performed in relation to the grant. Questioned costs $625 Context A portion of an employee’s benefits was improperly charged to the grant. Cause When the University changed their timekeeping platform an academic affairs employees’ compensation was improperly set up in the system which incorrectly allocated their vacation time to this grant. Effect The employee’s vacation time that occurred after the change in the University’s timekeeping platform in March 2025 until the discovery after year end was incorrectly included as compensation and benefits expense within the grant. Repeat finding No Recommendations We recommend that the University ensure controls are in place to adequately review all benefits pay charged to grants to ensure appropriate. View of responsible officials To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.
2025-002 - Lack of Written Federal Program Policies. Type: Material Weakness. Condition: The Village does not have documented policies and procedures specific to the administration of the Coronavirus State and Local Fiscal Recovery Funds program. This includes the absence of written guidance on key compliance areas such as payments, procurement, allowability of costs charged to federal programs, compensation, and travel costs under Uniform Guidance. Criteria: Per 2 CFR 200.303 and 200.331 of the Uniform Guidance, non-federal entities are required to establish and maintain effective internal controls and written policies to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. These policies should be tailored to the specific requirements of each federal program. Cause: The entity has not developed formal written policies and procedures for the Coronavirus State and Local Fiscal Recovery Funds program, possibly due to reliance on informal practices or general administrative policies that do not address federal-specific requirements. Effect: Without documented policies, there is an increased risk of noncompliance with federal requirements, inconsistent program administration, and lack of accountability. This may result in questioned costs, audit findings, or potential repayment of federal funds. Recommendation: We recommend that the Village develop and implement written policies and procedures specific to the Coronavirus State and Local Fiscal Recovery Funds program. These should include: - Payments in accordance with §200.302 (6), - Procurement in accordance with §200.318, - Allowability of costs charged to federal programs in accordance with §200.302 (7), - Compensation in accordance with §200.430 and §200.431, - Travel costs in accordance with §200.474. Training should also be provided to staff responsible for administering the program to ensure consistent application of these policies. Views of Responsible Officials: Management acknowledges the auditor’s finding regarding the absence of formally documented federal program policies. We recognize the importance of maintaining written procedures to ensure consistent compliance with Uniform Guidance requirements and to strengthen internal controls over federal awards. While informal practices have historically guided our federal program administration, we agree that formalizing these policies will enhance transparency, accountability, and operational efficiency. Management is currently in the process of developing written policies covering key areas such as procurement, allowable costs, subrecipient monitoring, and cash management. We anticipate completing this documentation and implementing the policies by February 28, 2026. We are committed to continuous improvement and appreciate the auditor’s recommendations as part of our efforts to maintain strong compliance and stewardship of federal funds.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. During payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 3 out of the 5 selected worklogs (60%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 12 and 32 working days (not including weekends) following the end of the pay period.Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
Criteria or Specific Requirement: Federal regulations (45 CFR 1635.4(a) and 2 CFR 200.430), state that federal award recipients must base allocations of salaries and wages costs to grants on records that accurately reflect the work performed. Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted: Payroll transactions: Eleven instances of errors totaling a net amount of $2,009 (an absolute value amount of $2,009) where the incorrect percentages were utilized in the allocation of the employee's pay, the incorrect employee's time was used in the allocation of the employee's pay, or there were unsupported amounts added to the allocation of the employee’s pay, and Payroll transactions: Seven instances of errors totaling a net amount of $109 (an absolute value amount of $4,405) where an unsupported allocation percentage was used to allocate the employee's pay to the grant - typically, employee salaries are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of an error totaling $91 where an unsupported allocation percentage was used to allocate employer-paid employee insurance costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of errors totaling $275 where employer-paid employee insurance and HSA contribution deductions per the employee's pay stub were allocated to the grant at a rate of 100%. Non-payroll and fringe transactions: one instance of an error totaling $884 where an unsupported allocation percentage was used to allocate general costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Additionally, we noted inconsistency in the general fund (LSC and two other private grants) allocation basis used during the year - grant hours and projected revenue were both utilized at different times during the year. Additionally, we noted that allocations in the general fund are done using projected revenue. However as revenue was recognized as expenses were incurred for the general fund the allocation based on revenue approximated an allocation method based on costs. As such, the costs mentioned above were allocated in an inconsistent manner to other grant costs and were not fully representative of the employees’ time and effort. However, we noted a lower frequency of differences in sample selections that occurred during the last several months of the year after management implemented a change to its allocation processes in response to the prior year audit. 2024 – 002: Cost Allocation of Expenses to LSC Grants (Continued) Questioned Costs: A net amount of $3,150 of allocated salary expense described above, which is related to Assistance Listing Number 09.706060. Context: These 23 instances were noting during testing of 55 disbursements. Cause: The Organization’s cost allocation methodology is primarily based on time and effort records, and periodic calculations of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund, but it often includes manual adjustments based on review of individual time records, expense and other data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities and in a manner where costs are not applied uniformly to both LSC (or, federally)-funded and non-LSC (of, federally) -funded activities. Repeat Finding: The finding is a repeat of findings in the immediately prior year. The prior year finding numbers were 2023-003 and 2023-004. Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Views of responsible officials: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Federal regulations state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities.
Criteria or Specific Requirement: Federal regulations (45 CFR 1635.4(a) and 2 CFR 200.430), state that federal award recipients must base allocations of salaries and wages costs to grants on records that accurately reflect the work performed. Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted: Payroll transactions: Eleven instances of errors totaling a net amount of $2,009 (an absolute value amount of $2,009) where the incorrect percentages were utilized in the allocation of the employee's pay, the incorrect employee's time was used in the allocation of the employee's pay, or there were unsupported amounts added to the allocation of the employee’s pay, and Payroll transactions: Seven instances of errors totaling a net amount of $109 (an absolute value amount of $4,405) where an unsupported allocation percentage was used to allocate the employee's pay to the grant - typically, employee salaries are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of an error totaling $91 where an unsupported allocation percentage was used to allocate employer-paid employee insurance costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of errors totaling $275 where employer-paid employee insurance and HSA contribution deductions per the employee's pay stub were allocated to the grant at a rate of 100%. Non-payroll and fringe transactions: one instance of an error totaling $884 where an unsupported allocation percentage was used to allocate general costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Additionally, we noted inconsistency in the general fund (LSC and two other private grants) allocation basis used during the year - grant hours and projected revenue were both utilized at different times during the year. Additionally, we noted that allocations in the general fund are done using projected revenue. However as revenue was recognized as expenses were incurred for the general fund the allocation based on revenue approximated an allocation method based on costs. As such, the costs mentioned above were allocated in an inconsistent manner to other grant costs and were not fully representative of the employees’ time and effort. However, we noted a lower frequency of differences in sample selections that occurred during the last several months of the year after management implemented a change to its allocation processes in response to the prior year audit. 2024 – 002: Cost Allocation of Expenses to LSC Grants (Continued) Questioned Costs: A net amount of $3,150 of allocated salary expense described above, which is related to Assistance Listing Number 09.706060. Context: These 23 instances were noting during testing of 55 disbursements. Cause: The Organization’s cost allocation methodology is primarily based on time and effort records, and periodic calculations of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund, but it often includes manual adjustments based on review of individual time records, expense and other data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities and in a manner where costs are not applied uniformly to both LSC (or, federally)-funded and non-LSC (of, federally) -funded activities. Repeat Finding: The finding is a repeat of findings in the immediately prior year. The prior year finding numbers were 2023-003 and 2023-004. Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Views of responsible officials: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Federal regulations state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities.
Criteria or Specific Requirement: Federal regulations (45 CFR 1635.4(a) and 2 CFR 200.430), state that federal award recipients must base allocations of salaries and wages costs to grants on records that accurately reflect the work performed. Federal regulations (45 CFR 1630.5 and 2 CFR 200.403) state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities. Condition: During our testing we noted: Payroll transactions: Eleven instances of errors totaling a net amount of $2,009 (an absolute value amount of $2,009) where the incorrect percentages were utilized in the allocation of the employee's pay, the incorrect employee's time was used in the allocation of the employee's pay, or there were unsupported amounts added to the allocation of the employee’s pay, and Payroll transactions: Seven instances of errors totaling a net amount of $109 (an absolute value amount of $4,405) where an unsupported allocation percentage was used to allocate the employee's pay to the grant - typically, employee salaries are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of an error totaling $91 where an unsupported allocation percentage was used to allocate employer-paid employee insurance costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Fringe-benefit transactions: Two instances of errors totaling $275 where employer-paid employee insurance and HSA contribution deductions per the employee's pay stub were allocated to the grant at a rate of 100%. Non-payroll and fringe transactions: one instance of an error totaling $884 where an unsupported allocation percentage was used to allocate general costs to the grant - typically, costs are allocated to LSC and two other private grants using an allocation base of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund. Additionally, we noted inconsistency in the general fund (LSC and two other private grants) allocation basis used during the year - grant hours and projected revenue were both utilized at different times during the year. Additionally, we noted that allocations in the general fund are done using projected revenue. However as revenue was recognized as expenses were incurred for the general fund the allocation based on revenue approximated an allocation method based on costs. As such, the costs mentioned above were allocated in an inconsistent manner to other grant costs and were not fully representative of the employees’ time and effort. However, we noted a lower frequency of differences in sample selections that occurred during the last several months of the year after management implemented a change to its allocation processes in response to the prior year audit. 2024 – 002: Cost Allocation of Expenses to LSC Grants (Continued) Questioned Costs: A net amount of $3,150 of allocated salary expense described above, which is related to Assistance Listing Number 09.706060. Context: These 23 instances were noting during testing of 55 disbursements. Cause: The Organization’s cost allocation methodology is primarily based on time and effort records, and periodic calculations of a LSC cost driver for the period divided by the total cost driver coded to the Organization’s general fund, but it often includes manual adjustments based on review of individual time records, expense and other data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities and in a manner where costs are not applied uniformly to both LSC (or, federally)-funded and non-LSC (of, federally) -funded activities. Repeat Finding: The finding is a repeat of findings in the immediately prior year. The prior year finding numbers were 2023-003 and 2023-004. Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Views of responsible officials: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Federal regulations state that expenditures are allowable under an LSC (or federal) grant or contract only if the recipient can demonstrate that the cost was consistent with accounting policies and procedures that apply uniformly to both LSC (or, federal)-funded and non-LSC (of, federal) -funded activities.
Significant deficiency in internal control over compliance and noncompliance related to allowable costs/cost principles compliance requirements. Federal Agency: U.S. Department of Treasury Pass-Through Entity: City and County of Denver Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: 202474319 Criteria Nonfederal entities must follow the standards for documentation of personnel expenses set out at 2 CFR section 200.430(i). Under those standards, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, those standards require that the records a) reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities; b) 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 nonfederal 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; and c) budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards. Budget estimates may be used for interim account purposes, provided that a) The system for establishing the estimates produces reasonable approximations of the activity performed; b) significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and c) the recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated Condition and Context The Organization maintains a timekeeping and payroll system for charges to federal awards that documents approved wage and salary rates, time and effort certification, hours, and actual amounts paid to employees. The Organization is allocating payroll costs to federal programs for individual employees using budget estimates of time and effort on different activities. The Organization maintains after-the-fact review documentation of time spent for each employee to support the allocation in the form of “Time and Effort” certifications that are signed by all employees and supervisors to verify actual time spent on major program. During our testing we noted two pay-periods for one employee where the Organization did not maintain the “Time and Effort” certification. Section III - Reportable Findings and Questioned Costs for Federal Awards Cause The Organization’s management noted that the missing certifications were due to the employee leaving employment before the certifications were completed for the two pay periods. The Organization did not have a process in place to ensure alternate certification documentation was created and retained in the situation of terminated employees. Effect The effect is that the Organization is not in compliance with the requirements of 2 CFR section 200.430(i) for the two pay periods for this employee. For two pay-periods for one employee the payroll costs charged to the major program were not supported by documentation of after-the-fact review evidencing that those costs reasonably reflect the work actually performed on the activity. Questioned Costs The expenditures for the two pay periods for the one employee totaled of $8,846. Repeat Finding This is not a repeat finding. Recommendation We recommend management update its internal control process for employees who depart or are unable to certify their timesheets to ensure all time spent on federal programs is certified by employees and their supervisors. Views of Responsible Official and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
Finding 2024-002 Payroll Information on the Federal Programs: 93.421 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR 200.430(i) of the Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of employees’ salaries among specific activities or cost objectives as required. Condition: During our review of payroll charges to Federal awards, we noted that BCHC did not use timesheets from January 2024 to August 2024 and recorded salaries based on budgeted allocations. In August 2024, timesheets were implemented but we noted that the time recorded in the general ledger did not coincide with the allocation on the actual timesheets. Cause: BCHC relied on predetermined budget estimates for payroll allocation rather than using timesheets that reflected actual hours worked. Effect or Potential Effect: There is a risk that payroll costs charged to Federal programs may not accurately represent the true level of effort, potentially resulting in unallowable costs being charged to Federal awards. Questioned Costs: Indeterminate-The questioned costs relate to salary and wage expenditures charged to Federal programs without the required time and effort documentation in accordance with 2 CFR §200.430. Specifically, employees whose compensation was allocated to Federal awards did not maintain timesheets or equivalent records reflecting actual time worked on specific Federal activities. Due to the absence of these records, we were unable to determine the portion of personnel costs that may be unallowable under Uniform Guidance. Accordingly, the questioned costs are considered indeterminate. Context: We sampled 40 payroll transactions. All transactions were based on budgeted amounts. This issue was observed across all departments receiving Federal funds. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: While BCHC now maintains timesheets, we recommend ensuring that payroll costs charged to Federal awards are based on the actual time recorded, rather than budgeted estimates. The timesheet data should be used to support allocations in accordance with Uniform Guidance, and adjustments should be made as needed to reflect the actual effort expended on Federal programs.
2024-001 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287 Material Weakness in Internal Control Over Compliance and Noncompliance – Inadequate Payroll Documentation B. Allowable Costs/Cost Principles Criteria: Per 2 CFR § 200.430(g), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. As part of the Organization’s internal controls, time and effort documentation—such as timecards—should be reviewed and approved by the employee to confirm accuracy. Condition and Context: We selected 40 individuals paid in randomly selected pay periods for testing. Our sample was not statistically valid. During our testing of payroll expenses charged to the federal program, we noted that 2 out of 40 of the employee timecards selected for review were not signed or electronically certified by the respective employee. Without employee attestation, the accuracy of the reported time cannot be verified in accordance with Uniform Guidance requirements. This resulted in total questioned costs of $763. Based on an error rate of 3.23%, the likely questioned costs for the full payroll population are projected to be $14,578. Additionally, we identified 10 instances where the number of hours reported on employee timecards did not match the hours recorded in the payroll system and charged to the federal award. The total questioned costs for these discrepancies were $569. Based on an error rate of 2.41%, the likely questioned costs for the full payroll population are projected to be $10,878. This is a repeat finding of 2023-003. Cause and Effect: The lack of employee signatures appears to be due to inconsistent enforcement of timecard approval procedures. The discrepancies in the number of hours charged to the federal award appear to be due to a lack of effective reconciliation procedures between timekeeping and payroll records. As a result of these items noted above, the Organization charged unsubstantiated payroll costs to the federal award. Recommendation: We recommend that management ensure all employee timecards are signed or electronically certified by the employee in a timely manner. We also recommend a process is implemented to reconcile time charge to federal award to underlying payroll report. Internal controls should be reinforced to verify that no payroll costs are charged to federal programs without appropriate documentation and approval. Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and updated our written policy in 2024. The policy was reviewed by the Finance Committee and approved by the full Board of Directors in December 2024.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.
Finding No. 2024-001: Allowable Cost/Activities (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.527 Health Center Program Cluster Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.527 Health Center Program Cluster. Time and effort reporting could not be located for the 7 employees that were charged to Grant H2E for the period September – December 2024 which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization did not follow the policies and procedures in place related to obtaining time and effort certifications from employees. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: $122,765 Context/Sampling: A sample of 40 payroll transactions were selected for testing. For each transaction, a timecard was obtained for all selected transactions which verified that the employees worked the hours to support the charges to the grant. While all timecards documented total hours worked, none included documentation of the specific time allocated to the federal program. Additionally, time and effort certifications were obtained for 33 of the 40 sampled employees. However, the Organization did not obtain time and effort certifications for the remaining 7 employees whose salaries were charged to the H2E grant. The sample was selected using non-statistical sampling methods and was not intended to be, nor should it be considered, a statistically valid sample. Repeat Finding: No Recommendation: Management should strengthen its internal controls over payroll charges to federal awards by ensuring consistent adherence to its time and effort certification policies as well as conduct periodic reviews of payroll documentation to verify compliance with established policies and federal requirements. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.
2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.
2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.
2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.
Finding No. 2024-001: Allowable Cost/Activities (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.527 Health Center Program Cluster Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.527 Health Center Program Cluster. Time and effort reporting could not be located for the 7 employees that were charged to Grant H2E for the period September – December 2024 which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization did not follow the policies and procedures in place related to obtaining time and effort certifications from employees. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: $122,765 Context/Sampling: A sample of 40 payroll transactions were selected for testing. For each transaction, a timecard was obtained for all selected transactions which verified that the employees worked the hours to support the charges to the grant. While all timecards documented total hours worked, none included documentation of the specific time allocated to the federal program. Additionally, time and effort certifications were obtained for 33 of the 40 sampled employees. However, the Organization did not obtain time and effort certifications for the remaining 7 employees whose salaries were charged to the H2E grant. The sample was selected using non-statistical sampling methods and was not intended to be, nor should it be considered, a statistically valid sample. Repeat Finding: No Recommendation: Management should strengthen its internal controls over payroll charges to federal awards by ensuring consistent adherence to its time and effort certification policies as well as conduct periodic reviews of payroll documentation to verify compliance with established policies and federal requirements. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.
Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.
Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.
Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.