2024-001. Allowable Costs/Cost Principles: Compensation – Personal Services United States Department of Education, Passed Through New York State, Department of Education: Twenty-First Century Community Learning Centers ALN: 84.287 Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee's compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The individual that was responsible for coordinating the program did not complete time and effort records, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: Time records for the balance of employees audited in our sample of 25, who were charged to federal awards by the District, were supportive of amounts included in budgets approved by the State and included in the Final Expenditure Report. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should monitor its procedures to ascertain that documentation to support salaries and wages charged to federal awards is in a format that complies with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District agrees with the finding. Peter Daly, Interim School Business Administrator, will oversee the monitoring of procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles: Compensation – Personal Services United States Department of Education, Passed Through New York State, Department of Education: Twenty-First Century Community Learning Centers ALN: 84.287 Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee's compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The individual that was responsible for coordinating the program did not complete time and effort records, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: Time records for the balance of employees audited in our sample of 25, who were charged to federal awards by the District, were supportive of amounts included in budgets approved by the State and included in the Final Expenditure Report. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should monitor its procedures to ascertain that documentation to support salaries and wages charged to federal awards is in a format that complies with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District agrees with the finding. Peter Daly, Interim School Business Administrator, will oversee the monitoring of procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
Department of Health and Human Services FFAL #93.696, 1H79SM087069, 9/30/2022 – 9/30/2026 Certified Community Behavior Health Clinic Expansion Grants Activities Allowed or Unallowed and Allowable Costs and Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: The Center is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E – Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the office records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) 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. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee’s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: In our sample of expenditures selected for testing, we noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (1 instances). b) Calculation errors for expenses allocated to the grant (3 instances). c) Employee tracked 2.7 hours under the federal program and a nonfederal program line in ClickTime (1 instance) causing it to be double counted. Cause: An employee entered 8 hours of PTO into ClickTime for two days each; however, the employee was only paid for 4 hours of PTO for each day. The calculation errors were due to the use of a wrong employee’s allocation percentage and a keying error for payroll expenses for an employee. The secondary review of the employee ClickTime timecards did not identify the incorrectly tracked hours and double tracked time. Also, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. Effect: The Center’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: The program was overcharged by $1,134. Context: A total non-statistical sample of 60 nonpayroll and payroll transactions out of more than 250 transactions were selected for testing, which accounted for $239,541 of $886,400 of federal payroll and nonpayroll direct program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend management review the procedures and control processes involving timecards, allocating payroll expenses and the federal grant expenditure tracking spreadsheet to ensure compliance with the federal grant. Views of Responsible Officials: Management is in agreement.
Significant Deficiency / Other Non-compliance Federal Agency U.S. Department of Education Pass-through: Mississippi Department of Education Assistance Listing Numbers: 84.425 U Program Title: COVID-19-Elementary & Secondary School Emergency Relief Fund (ESSER) ARP III Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles. Repeat Finding from prior year: No Prior Year Finding Number: N/A Criteria: 2 CFR Section 200.430(g) specifies 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 and 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, the district’s Federal Programs Procedural Handbook states “ Salaries and wages paid for North Tippah employees who work on a single federal cost object must be supported by periodic certifications that the employees worked solely on that activity for the period covered by the certification. These certifications must be prepared at least semi-annually, then signed and dated by the employee and supervisory administrator that has firsthand knowledge of the employee’s work. North Tippah Employees who work on multiple cost objectives must support the distribution of their salaries or wages by completing personnel activity reports These personnel activity reports must reflect an after the fact distribution of the actual activity; must account for the total activity for which the employee is compensated; must be prepared at least monthly, coinciding with one or more pay periods; and the PAR shall have a legible handwritten signature signed and dated by employee and supervisory administrator that has firsthand knowledge of the employee’s work. Condition: The district failed to follow the their policies and procedures regarding time and effort documentation, as a result time and effort documentation for seven employees were not available for audit. Context/Perspective This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and follow the District’s documented internal controls procedures. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants or monthly personnel activity reports (PAR) for employees who work on more that one cost objective. Questioned Cost: None Views of responsible officials of the auditee: See Auditee’s Corrective Action Plan
Federal Program Title: Staffing for Adequate Fire & Emergency Response Federal Catalog Number: 97.083 Federal Agency: U.S. Department of Homeland Security Category of Finding: Activities Allowed/Unallowed Criteria: According to 2 CFR 200.430, employees working on federally funded projects are required to submit timesheets that accurately reflect the time spent on the project. These timesheets must be approved by a responsible supervisor to ensure that the reported hours are accurate, reasonable, and properly allocated. Additionally, organizations must establish and maintain effective internal controls to ensure compliance with timekeeping and payroll procedures. Condition: During the audit, it was found that the City's time roster report approval process was not consistently followed. We selected four pay periods for testing. In two of these periods, the time roster reports were not properly reviewed and approved by a battalion chief supervisor before submission for payroll processing. These time roster reports were automatically approved by the system to meet payroll processing deadlines, bypassing the required supervisory review. Cause: The failure to adhere to the time roster report approval process was due to a lack of oversight and insufficient enforcement of internal control procedures. Effect or Potential Effect: The lack of proper time roster approval creates a risk of inaccuracies in the allocation of payroll costs to federal grants, which could result in non-compliance with federal regulations. Additionally, failure to follow the required process could lead to improper charging of labor costs, potentially jeopardizing the City’s eligibility for future funding and risking the disallowance of grant-related costs. Questioned Cost: None. Repeat of a Prior-Year Finding: No. Recommendation: We recommend the City to strengthen its internal controls related to time roster report approval. Specifically, a formal time roster report approval process should be implemented that includes clear guidelines for timely approval by supervisors. The City should also establish a tracking system to ensure that time roster report is approved before submission for payroll processing. Regular training for staff and supervisors on the importance of accurate timekeeping and approval procedures should be conducted to reinforce compliance with federal grant requirements. Management Response and Corrective Action Plan City's Response: The City uses Telestaff to maintain Fire employees’ work schedules and as the system of record for payroll timekeeping. The audit identified several rosters that were not finalized (approved) by the Duty Chief before the conclusion of their shift and were auto-finalized by the system. Going forward, the City will ensure that the finalization process by the Duty Chief, which essentially serves to confirm that the time and attendance as reflected in Telestaff is what was actually worked, is adhered to. Oxnard Fire Department Policy 1005 requires that the Duty Chief review and approve the roster at the conclusion of their shift to verify the accuracy of the roster for payroll processing. In instances where overtime related to late relief is in unapproved status (depicted with an asterisk in the system), the Duty Chief will ensure the late relief is approved before finalizing the daily roster. After the roster is finalized (approved) by the Duty Chief, the timekeeper reviews the roster for the appropriate general ledger account(s), paycode(s), and project coding to ensure proper accounting of payroll costs. If the Duty Chief has not finalized the roster by 0800, the timekeeper will inform the Department Assistant Chiefs to initiate completion of the task. Corrective Action Plan: The Department will conduct a formal review of its processes and policies to identify potential weaknesses in the payroll timekeeping and approval process, and will update its policies and procedures to align with the roles and responsibilities of those involved in rostering and timekeeping. The department has already taken corrective action to ensure that duty chiefs are finalizing the rosters before the end of their shift and making it the responsibility of the timekeeper to initiate action when finalization by the Duty Chiefs has not occurred so the timekeepers review process can be completed. Planned Implementation Date: June 30, 2025 Responsible Person(s): Karsten Guthrie and Rose Rodarte
Criteria: Federal regulations 2 CFR Part 200, Sect 200.430(g) requires that wages chargerd to federal programs, including amounts claimed or used for matching, must be based on records that accuratley reflect work performed. Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes (with restrictions). Condition: The Alliance did maintain acurate time sheeets for time worked, however time was alloacted to the federal grant based on the year-to-date percentag eof time spent on the federal program and was not adjusted to actual time spent based on the pay period and times worked in the corresponding pay period. Additionally, fringe benefits were not allocated to the federal program based on time worked in the federal program. Cause: Management was unaware of the requirement to adjust to actual time spent on the federal program. Effect: Wages, payroll taxes and fring benefits charged to the federal program are in excess of actutal amounts based on time spent working in the federal program. Questions costs: $33,921. Recommendation: We recommend that mamangement allocate time to federal programs based on time spent per pay period. If estimates will be used during the fiscal year, an adjustment should be made at year-end to adjust to actual time worked in the federal program. Additionally, fringe benefits should be allocated to the fedral program in a manner consistent with the pattern of benefits attributable to employees whose salaries are chargebable to the federal award. View of Responsible Officials: Management agrees with the finding and recommendation. See attached Corrective Action Plan.
2024 – 002 Allowable Costs Federal Agency: U.S. Department Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425U, 84.425D, 84.425W Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: S425U210013, S425D210013, S425W210013 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Criteria or specific requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that payroll expenses were charged to the grant program based upon an allocation from the budget and not on approved and/or certified time worked in the program. Questioned costs: $234,052 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program. Cause: Salary figures for salaried employees were charged to the federal grant based on unapproved work actually performed for the program. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No. Recommendation: We recommend the School ensure policies and procedures for payroll expenditures for grant programs be charged to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002 Allowable Costs Federal Agency: U.S. Department Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425U, 84.425D, 84.425W Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: S425U210013, S425D210013, S425W210013 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Criteria or specific requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that payroll expenses were charged to the grant program based upon an allocation from the budget and not on approved and/or certified time worked in the program. Questioned costs: $234,052 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program. Cause: Salary figures for salaried employees were charged to the federal grant based on unapproved work actually performed for the program. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No. Recommendation: We recommend the School ensure policies and procedures for payroll expenditures for grant programs be charged to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002 Allowable Costs Federal Agency: U.S. Department Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425U, 84.425D, 84.425W Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: S425U210013, S425D210013, S425W210013 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Criteria or specific requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that payroll expenses were charged to the grant program based upon an allocation from the budget and not on approved and/or certified time worked in the program. Questioned costs: $234,052 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program. Cause: Salary figures for salaried employees were charged to the federal grant based on unapproved work actually performed for the program. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No. Recommendation: We recommend the School ensure policies and procedures for payroll expenditures for grant programs be charged to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2024-004 Community Development Block Grants, ALN 14.218 Federal Award Identification Number and Year: B-23-MC-25-0019, 2024 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: (CFR) Title 2 Part 200.430 indicates 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For one of forty payroll disbursements in our sample, evidence of management's review of time and effort was not provided. Questioned Costs: None. Cause: Procedures were not implemented effectively to ensure all attestations of time and effort were reviewed and approved by supervising officials. Effect: While time and effort dedicated to cost objectives was documented for the instance in questions, the risk of noncompliance with federal program requirements is present due to the lack of approval from the payroll documentation. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure management's review and approval of time and effort attestation is present on supporting documentation maintained for payroll costs. Views of Responsible Officials: Management agrees with the finding.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
2024-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430. Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, prepared annual periodic certification reports using amounts based on budgets for time performance prior to the work being completed. The reports were not updated to reflect actual time performance amounts. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award. Questioned Costs: None reported. Context: The District maintains time records for employees charged to federal awards in accordance with approved budgets. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its procedures to prepare documentation to support actual salaries and wages charged to federal awards after the work was performed in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.
MATERIAL WEAKNESS IN INTERNAL CONTROLS OVER FINANCIAL REPORTING Criteria: Management is responsible for maintaining a system of internal controls over the preparation of the financial statements and all required footnotes that are free of material errors and are in accordance with generally accepted accounting principles (GAAP). This includes preparing and/or thoroughly reviewing the GAAP based financial statements to ensure they are free of material misstatement, retaining documentation of entries made, and maintaining proper internal controls to ensure reconciliations are completed, maintained and accurate. As described in Section III – FEDERAL PROGRAM AUDIT FINDINGS (Section III), testing during the audit identified that management did not track grant specific expenses in separate ledgers within the accounting system as well as salary and benefits charged to certain federal programs were based solely on budget. There were no records able to be provided of actual time spent on each grant by employee, and therefore, management was unable to provide documentation of a review of actual time charged to each program to determine it was accurate, allowable and properly allocated. Further details regarding the criteria, condition, cause, and other finding elements may be found in Section III. Condition: The Organization’s year end close procedures did not adequately address the completeness, existence, and accuracy of the financial statements. Material audit adjustments Cause: The Organization’s internal control procedures were not designed to adequately detect material misstatements. Effect: A material audit adjusting journal entry related to revenues and receivables. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that as part of its internal controls over the preparation of financial statements, the Organization should implement a more effective and comprehensive, and documented financial statement close and review process, to ensure that the financial statements are complete and accurate. Views of Responsible Officials and Corrective Action Plan: See corrective action plan attached to financial statements. Criteria: Management did not track grant specific expenses in separate ledgers within the accounting system. Tracking expenses within separate ledgers provides assurance that grant expenses are being allocated properly and duplicate submissions under multiple grants is avoided. Title 2, Subtitle A, Chapter 200, Subpart E, § 200.430 of the Code of Federal Regulations states that “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 that provides reasonable assurance that the charges are accurate, allowable and properly allocated” and “(vii) Budget estimated (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed;” 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: Testing over Assistance Listing #21.027 - Coronavirus State and Local Fiscal Recovery Funds indicated grant expenses were not recorded within separate ledgers leading to difficulty in gaining assurance that grant expenses were billed properly to each respective grant and that expenses were only billed to their applicable grants. Testing over Assistance Listing #21.027 - Coronavirus State and Local Fiscal Recovery Funds indicated that salaries charged to that Federal award were based on budgeted amount. There was no documentation of the required periodic after-the-fact review of the budgeted amounts applied to ALN 21.027 that management was able to provide during the audit process. Cause: Management was unaware of grant reporting requirements leading to non-separately reported grant data and allocation of payroll based on estimates. Effect: Little assurance that grant allocations were being done correctly and that grant expenses were not being billed to multiple grants. Payroll expenses being allocated based on estimates instead of actual time spent leading to uncertainty of validity of payroll expenses being billed to grants. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management takes the steps necessary to understand and implement the controls needed in order to maintain compliance for new and unusual funding. Views of Responsible Officials and Corrective Action Plan: See corrective action plan attached to financial statements
Assistance Listing Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Award Number: N/A Federal Award Year: 2023/2024 Pass Through Entity: Chicago Cook Workforce Partnership Criteria: In accordance with 2 CFR 200.303, 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. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by0 the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) - spacing 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization’s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: See corrective action plan attached to financial statements.
Federal Agencies: Department of Health and Human Services Federal Assistance Listing Number: 93.696 Program: Certified Community Behavioral Health Clinic Expansion Grants Award/Pass-Through Entity Identifying Number: H79SM086589 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal 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, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that KMHS allocated payroll expenditures using budgeted allocation rates that were not trued up to actual. One out of 11 payroll selections used budgeted allocation rates that needed to be adjusted down to actual. Cause: KMHS did not have adequate policies/procedures in place to ensure fringe allocations are trued down to actual if applicable. KMHS relied heavily on manual processes that are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, KMHS could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement KMHS is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of KMHS’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits towards the program in 2024 were $861,659. The over-allocation of fringe benefits in excess of actuals is considered questioned costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend implementing system improvements to compare budget to actual fringe expenditures and complete reconciliations when necessary. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the allocation procedures.
Department of Health and Human Services 2024-002 (Repeat finding 2023-003) Block Grants for Community Mental Health Services Criteria: Under 2 CFR 200.430(i)(1)(i) charges to Federal Awards for salaries and wages must be based on records that accurately reflect work performed and be supported with documentation that reasonable assure that the charges are accurate, allowable, and properly allocation and reasonably reflect the total activity for which the employee is compensated. Condition: The documentation to support reasonable assurance for salaries and wages consisted of documentation of when employees completed a therapy session but no clear documentation of how much time when employees were on-call or completed case notes for this grant. Cause: The documentation to support time and effort of employee’s salaries did not include all of the hour’s employees spent on the grant. The Center employees spend hours working outside the therapy session that relate to providing the best help for their clients’ needs. Effect: There is not proper documentation to support the allocation of time and effort that was charged to the grant. Auditor’s Recommendation: We recommend The Center remind its employees complete a personnel activity report that show all of the hours employees spend on the grant not rely just hours documented in the Center system used to track therapy sessions. Management response: Management agrees with the finding and already has a process in place for documenting time spent on grant funded activities. Management is working with our Chief Compliance Officer to ensure that the process encompasses all necessary steps to ensure complete and accurate records of the grant related activities by those who have the time covered by the grant funds.
2024-006 Program: Equitable Sharing Program Federal Financial Assistance Listing Number: 16.922 Federal Grantor: U.S. Department of Justice Award No. and Year: 2024 Compliance Requirements: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, 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. 2 CFR Section 200.430, Compensation – Personal Services, 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: During our testing of the Sheriff Department’s compliance with allowable costs/cost principles requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were miscalculated. Cause: Equitable sharing funds may not be used for salaries, except under certain provisions outlined in Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department calculates the allowable portion of personnel salaries using a separate template that contained a formula error which inaccurately calculated the total salaries costs allocated to the program. The Sheriff’s department did not have internal controls in place to ensure that the allowed salaries were being calculated correctly. However, the error was detected after the 5th out of 6 months in which these types of costs were allocated to the program. Effect: Salary costs were allocated to the program in an incorrect amount. Questioned Costs: Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned costs for the total population was $23,409. Context/Sampling: A sample of forty (40) individuals were selected from a population consisting of (840) payroll transactions. Repeat Finding from Prior Years: No. Recommendation: We recommend the Sheriff’s Department establish and maintain internal controls to ensure the overtime calculations are being accurately allocated to the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program Federal Financial Assistance Listing Number: 16.922 Federal Grantor: U.S. Department of Justice Award No. and Year: 2024 Compliance Requirements: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, 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. 2 CFR Section 200.430, Compensation – Personal Services, 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: During our testing of the Sheriff Department’s compliance with allowable costs/cost principles requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were miscalculated. Cause: Equitable sharing funds may not be used for salaries, except under certain provisions outlined in Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department calculates the allowable portion of personnel salaries using a separate template that contained a formula error which inaccurately calculated the total salaries costs allocated to the program. The Sheriff’s department did not have internal controls in place to ensure that the allowed salaries were being calculated correctly. However, the error was detected after the 5th out of 6 months in which these types of costs were allocated to the program. Effect: Salary costs were allocated to the program in an incorrect amount. Questioned Costs: Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned costs for the total population was $23,409. Context/Sampling: A sample of forty (40) individuals were selected from a population consisting of (840) payroll transactions. Repeat Finding from Prior Years: No. Recommendation: We recommend the Sheriff’s Department establish and maintain internal controls to ensure the overtime calculations are being accurately allocated to the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program Federal Financial Assistance Listing Number: 16.922 Federal Grantor: U.S. Department of Justice Award No. and Year: 2024 Compliance Requirements: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, 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. 2 CFR Section 200.430, Compensation – Personal Services, 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: During our testing of the Sheriff Department’s compliance with allowable costs/cost principles requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were miscalculated. Cause: Equitable sharing funds may not be used for salaries, except under certain provisions outlined in Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department calculates the allowable portion of personnel salaries using a separate template that contained a formula error which inaccurately calculated the total salaries costs allocated to the program. The Sheriff’s department did not have internal controls in place to ensure that the allowed salaries were being calculated correctly. However, the error was detected after the 5th out of 6 months in which these types of costs were allocated to the program. Effect: Salary costs were allocated to the program in an incorrect amount. Questioned Costs: Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned costs for the total population was $23,409. Context/Sampling: A sample of forty (40) individuals were selected from a population consisting of (840) payroll transactions. Repeat Finding from Prior Years: No. Recommendation: We recommend the Sheriff’s Department establish and maintain internal controls to ensure the overtime calculations are being accurately allocated to the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.