Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: 2 CFR 200.430(h)(8)(i) requires that amounts of personnel expenses are properly documented and include appropriate controls and documentation to support the distribution of the employee's wages among specific activities if the employee works on more than one award. Condition: Of the testing population of 120 payroll transactions tested, for 2 transactions the Organization was unable to provide a timesheet or other documentation to substantiate the application of the individual's time for that period. In addition for 59 transactions, the allocation on the time sheet provided does not agree to the allocation of the individual's wages to the program in the general ledger and voucher. Cause: Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. Effect: The Organization is not able to demonstrate that the personnel expenses allocated to the grant was proper and ensure avoidance of duplication of funding requests for the same amounts. Questioned Costs: Unknown Recommendation: Management should review and refine its process of tracking payroll costs by grant to ensure that the costs are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, are properly allocated, and reasonably reflect the total activity for which the employee is compensated. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Finding 2024-010 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.010, 93.600 Federal Program Name: Title I Grants to Local Educational Agencies and Head Start Cluster Federal Agency Name: U.S. Department of Education and U.S. Department of Health and Human Services Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIA-141, 2024-403619-DPI-CSI-148 Criteria: In accordance with 2 CFR 200.303(a), 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. In accordance with 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under Federal awards. Condition/Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Cause: There was a lack of internal control over the timely approval of the semi-annual certifications. Effect or Potential Effect: By not having an approved semi-annual certification before the date of the final reimbursement claims, unallowable costs may be submitted for reimbursement. Questioned Costs: The payroll costs and related fringe benefits charged at a rate of 52.48% are unallowable. Title I Grants to Local Educational Agencies (ALN 84.010) • 2024-403619-DPI-CSI-148: The two sampled individuals’ payroll and fringe benefits for the particular transaction totaled $507. • 2024-403619-DPI-TIA-141: The additional individuals' payroll and fringe benefits for the spring semi-annual certifications reviewed that were approved after the final reimbursement submission date and those that were not approved at all totaled $2,077,880. Head Start Cluster (ALN 93.600) • 05CH010537: After the additional testing, the total payroll and related fringe benefits for the spring semi-annual certifications that were approved after the final reimbursement request submission date or not approved at all totaled $241,794. Recommendations: We recommend that controls be implemented that will allow costs to be reviewed and fully supported prior to the date the final reimbursement claims are due to DPI. Views of Responsible Official: Management concurs with the finding.
Finding 2024-010 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.010, 93.600 Federal Program Name: Title I Grants to Local Educational Agencies and Head Start Cluster Federal Agency Name: U.S. Department of Education and U.S. Department of Health and Human Services Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIA-141, 2024-403619-DPI-CSI-148 Criteria: In accordance with 2 CFR 200.303(a), 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. In accordance with 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under Federal awards. Condition/Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Cause: There was a lack of internal control over the timely approval of the semi-annual certifications. Effect or Potential Effect: By not having an approved semi-annual certification before the date of the final reimbursement claims, unallowable costs may be submitted for reimbursement. Questioned Costs: The payroll costs and related fringe benefits charged at a rate of 52.48% are unallowable. Title I Grants to Local Educational Agencies (ALN 84.010) • 2024-403619-DPI-CSI-148: The two sampled individuals’ payroll and fringe benefits for the particular transaction totaled $507. • 2024-403619-DPI-TIA-141: The additional individuals' payroll and fringe benefits for the spring semi-annual certifications reviewed that were approved after the final reimbursement submission date and those that were not approved at all totaled $2,077,880. Head Start Cluster (ALN 93.600) • 05CH010537: After the additional testing, the total payroll and related fringe benefits for the spring semi-annual certifications that were approved after the final reimbursement request submission date or not approved at all totaled $241,794. Recommendations: We recommend that controls be implemented that will allow costs to be reviewed and fully supported prior to the date the final reimbursement claims are due to DPI. Views of Responsible Official: Management concurs with the finding.
Finding 2024-010 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.010, 93.600 Federal Program Name: Title I Grants to Local Educational Agencies and Head Start Cluster Federal Agency Name: U.S. Department of Education and U.S. Department of Health and Human Services Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIA-141, 2024-403619-DPI-CSI-148 Criteria: In accordance with 2 CFR 200.303(a), 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. In accordance with 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under Federal awards. Condition/Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Cause: There was a lack of internal control over the timely approval of the semi-annual certifications. Effect or Potential Effect: By not having an approved semi-annual certification before the date of the final reimbursement claims, unallowable costs may be submitted for reimbursement. Questioned Costs: The payroll costs and related fringe benefits charged at a rate of 52.48% are unallowable. Title I Grants to Local Educational Agencies (ALN 84.010) • 2024-403619-DPI-CSI-148: The two sampled individuals’ payroll and fringe benefits for the particular transaction totaled $507. • 2024-403619-DPI-TIA-141: The additional individuals' payroll and fringe benefits for the spring semi-annual certifications reviewed that were approved after the final reimbursement submission date and those that were not approved at all totaled $2,077,880. Head Start Cluster (ALN 93.600) • 05CH010537: After the additional testing, the total payroll and related fringe benefits for the spring semi-annual certifications that were approved after the final reimbursement request submission date or not approved at all totaled $241,794. Recommendations: We recommend that controls be implemented that will allow costs to be reviewed and fully supported prior to the date the final reimbursement claims are due to DPI. Views of Responsible Official: Management concurs with the finding.
Finding 2024-010 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.010, 93.600 Federal Program Name: Title I Grants to Local Educational Agencies and Head Start Cluster Federal Agency Name: U.S. Department of Education and U.S. Department of Health and Human Services Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIA-141, 2024-403619-DPI-CSI-148 Criteria: In accordance with 2 CFR 200.303(a), 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. In accordance with 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under Federal awards. Condition/Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Cause: There was a lack of internal control over the timely approval of the semi-annual certifications. Effect or Potential Effect: By not having an approved semi-annual certification before the date of the final reimbursement claims, unallowable costs may be submitted for reimbursement. Questioned Costs: The payroll costs and related fringe benefits charged at a rate of 52.48% are unallowable. Title I Grants to Local Educational Agencies (ALN 84.010) • 2024-403619-DPI-CSI-148: The two sampled individuals’ payroll and fringe benefits for the particular transaction totaled $507. • 2024-403619-DPI-TIA-141: The additional individuals' payroll and fringe benefits for the spring semi-annual certifications reviewed that were approved after the final reimbursement submission date and those that were not approved at all totaled $2,077,880. Head Start Cluster (ALN 93.600) • 05CH010537: After the additional testing, the total payroll and related fringe benefits for the spring semi-annual certifications that were approved after the final reimbursement request submission date or not approved at all totaled $241,794. Recommendations: We recommend that controls be implemented that will allow costs to be reviewed and fully supported prior to the date the final reimbursement claims are due to DPI. Views of Responsible Official: Management concurs with the finding.
Finding - Contrary to Federal regulations, District records did not always accurately reflect employee work performed for, and support the distribution of employee salaries and benefits charged to, the SEC. Criteria - Title 2, Section 200.430(i), CFR, requires that charges for Federal awards for salaries be based on records that accurately reflect the work performed and support the distribution of employee salaries among specific activities or cost objectives if the employee works on more than one Federal award or a Federal award and non-Federal award. In addition, Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over the SEC. To ensure that charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel (e.g., the Exceptional Student Education Director) who possess adequate knowledge and experience of program requirements. Condition - For the 2023-24 fiscal year the District reported SEC expenditures totaling $1.8 million, including $1.5 million for salaries and benefits for 83 employees. To determine the propriety and allowability of SEC expenditures, we requested for examination District records supporting salaries and benefits totaling $628,953 charged to the SEC for 16 employees. Although we requested, District records were not provided to identify the work that the 16 employees performed to support the salaries and benefits charged to the SEC. Cause - The District did not always maintain records to identify the work employees performed to support the salaries and benefits charged to the SEC, and an employee with knowledge and experience of the SEC requirements was not required to, and did not, document review and approval of the salary and benefit charges. Effect - Absent effective procedures to document support for the distribution of employee salaries and benefits to the SEC, including the documented review and approval of those charges by the Exceptional Student Education Director or other personnel with knowledge and experience of SEC requirements, there is an increased risk that expenditures may be inappropriately charged to the SEC. We expanded our procedures to interview the 16 employees and determined that their salaries and benefits were appropriately charged to the SEC. However, our procedures cannot substitute the District’s responsibility to ensure that salaries and benefits charged to the SEC are properly supported. Recommendation - The District should establish procedures to ensure that District records accurately reflect the work performed to support the distribution of employee salaries and benefits charged to the SEC. Such procedures should require that the Exceptional Student Education Director or other personnel with appropriate knowledge and experience document review and approval of those charges. District Response - The District is in the process of reviewing and updating controls to ensure required time and effort logs are kept in the District's fiscal management system and routine submission of forms is enforced by the grant managers.
Finding - Contrary to Federal regulations, District records did not always accurately reflect employee work performed for, and support the distribution of employee salaries and benefits charged to, the SEC. Criteria - Title 2, Section 200.430(i), CFR, requires that charges for Federal awards for salaries be based on records that accurately reflect the work performed and support the distribution of employee salaries among specific activities or cost objectives if the employee works on more than one Federal award or a Federal award and non-Federal award. In addition, Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over the SEC. To ensure that charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel (e.g., the Exceptional Student Education Director) who possess adequate knowledge and experience of program requirements. Condition - For the 2023-24 fiscal year the District reported SEC expenditures totaling $1.8 million, including $1.5 million for salaries and benefits for 83 employees. To determine the propriety and allowability of SEC expenditures, we requested for examination District records supporting salaries and benefits totaling $628,953 charged to the SEC for 16 employees. Although we requested, District records were not provided to identify the work that the 16 employees performed to support the salaries and benefits charged to the SEC. Cause - The District did not always maintain records to identify the work employees performed to support the salaries and benefits charged to the SEC, and an employee with knowledge and experience of the SEC requirements was not required to, and did not, document review and approval of the salary and benefit charges. Effect - Absent effective procedures to document support for the distribution of employee salaries and benefits to the SEC, including the documented review and approval of those charges by the Exceptional Student Education Director or other personnel with knowledge and experience of SEC requirements, there is an increased risk that expenditures may be inappropriately charged to the SEC. We expanded our procedures to interview the 16 employees and determined that their salaries and benefits were appropriately charged to the SEC. However, our procedures cannot substitute the District’s responsibility to ensure that salaries and benefits charged to the SEC are properly supported. Recommendation - The District should establish procedures to ensure that District records accurately reflect the work performed to support the distribution of employee salaries and benefits charged to the SEC. Such procedures should require that the Exceptional Student Education Director or other personnel with appropriate knowledge and experience document review and approval of those charges. District Response - The District is in the process of reviewing and updating controls to ensure required time and effort logs are kept in the District's fiscal management system and routine submission of forms is enforced by the grant managers.
Finding - Contrary to Federal regulations, District records did not always accurately reflect employee work performed for, and support the distribution of employee salaries and benefits charged to, the SEC. Criteria - Title 2, Section 200.430(i), CFR, requires that charges for Federal awards for salaries be based on records that accurately reflect the work performed and support the distribution of employee salaries among specific activities or cost objectives if the employee works on more than one Federal award or a Federal award and non-Federal award. In addition, Title 2, Section 200.303(a), CFR, requires the District to maintain effective internal controls over the SEC. To ensure that charges are allowable, an appropriate system of internal controls requires that review and approval of program or grant expenditures be performed by personnel (e.g., the Exceptional Student Education Director) who possess adequate knowledge and experience of program requirements. Condition - For the 2023-24 fiscal year the District reported SEC expenditures totaling $1.8 million, including $1.5 million for salaries and benefits for 83 employees. To determine the propriety and allowability of SEC expenditures, we requested for examination District records supporting salaries and benefits totaling $628,953 charged to the SEC for 16 employees. Although we requested, District records were not provided to identify the work that the 16 employees performed to support the salaries and benefits charged to the SEC. Cause - The District did not always maintain records to identify the work employees performed to support the salaries and benefits charged to the SEC, and an employee with knowledge and experience of the SEC requirements was not required to, and did not, document review and approval of the salary and benefit charges. Effect - Absent effective procedures to document support for the distribution of employee salaries and benefits to the SEC, including the documented review and approval of those charges by the Exceptional Student Education Director or other personnel with knowledge and experience of SEC requirements, there is an increased risk that expenditures may be inappropriately charged to the SEC. We expanded our procedures to interview the 16 employees and determined that their salaries and benefits were appropriately charged to the SEC. However, our procedures cannot substitute the District’s responsibility to ensure that salaries and benefits charged to the SEC are properly supported. Recommendation - The District should establish procedures to ensure that District records accurately reflect the work performed to support the distribution of employee salaries and benefits charged to the SEC. Such procedures should require that the Exceptional Student Education Director or other personnel with appropriate knowledge and experience document review and approval of those charges. District Response - The District is in the process of reviewing and updating controls to ensure required time and effort logs are kept in the District's fiscal management system and routine submission of forms is enforced by the grant managers.
Federal Program Information: Assistance Listing Number: 93.959 Federal Program Title: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004383-W2, PH-004383-W1 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Assistance Listing Number: 93.531 Federal Program Title: Community Transformation Grants and National Dissemination and Support for Community Transformation Grants Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004921 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria: Per the Uniform Guidance, 2 CFR §200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the actual work performed. Budget estimates may be used for interim purposes, but must be supported by contemporaneous documentation, reconciled to actual time worked, and adjusted as necessary. Additionally, 2 CFR §200.403(d) requires that costs be allocated to federal awards in accordance with the relative benefits received. The OMB Compliance Supplement (Part 6 – Internal Control and Part 3 – Compliance Requirements) reinforces that payroll and nonpayroll costs must be supported by reliable records and allocated using reasonable and consistent methodologies. Condition: During the testing of payroll costs, we noted that for Federal Assistance Listings 93.959 and 93.531, payroll charges in 4 out of 40 samples and 2 out of 11 samples, respectively, were based on budgeted rates rather than actual hours worked. Supporting documentation (e.g., timesheets or equivalent records) was not used to substantiate the final charges, and adjustments to actual time and effort were not made. For nonpayroll costs, we identified that in 3 out of 40 samples (93.959) and 5 out of 18 samples (93.531), costs were not allocated using a consistent and reasonable basis across all benefiting programs. Instead, the Organization either charged costs by maximizing the allowable budget under each program or have inadvertently used an incorrect basis due to oversight. Cause: The deficiencies occurred because the Organization’s internal controls were not sufficiently designed or implemented to ensure compliance with Uniform Guidance requirements. Specifically, payroll costs were charged to federal awards based on budget estimates rather than actual time and effort supported by records such as timesheets, and nonpayroll costs were either maximized to the budget or were allocated using an incorrect basis. These control gaps in review and documentation resulted in costs being charged to federal programs in a manner inconsistent with Allowable Costs/Cost Principles. Effect: As a result of these deficiencies, federal program expenditures reported to the awarding agency were misstated. Our testing identified questioned costs across both programs, consisting of payroll and nonpayroll overallocations. These represent unallowable costs under Uniform Guidance and may be subject to disallowance. Inaccurate cost allocations increase the risk of noncompliance with federal requirements, could lead to repayment of disallowed costs, and may negatively affect future federal funding decisions. Questioned Costs: Known and extrapolated costs for payroll and nonpayroll costs for Federal Assistance Listings 93.959 and 93.531 are summarized below. These amounts represent the overallocation to the programs, representing unallowable costs under Uniform Guidance. Recommendation: We recommend that the Organization strengthen its internal controls over payroll and nonpayroll cost allocations by requiring time and effort records to support all payroll charges to federal awards, ensuring nonpayroll costs are allocated using documented and equitable methodologies, and performing regular reconciliations of budgeted amounts to actual costs. In addition, staff responsible for preparing and reviewing cost allocations should receive training on Uniform Guidance requirements to ensure accuracy, compliance, and consistency across all federal programs. Views of responsible officials and planned corrective actions: For payroll, procedures will be implemented to ensure that payroll costs allocated to federal grants are supported by actual time. For nonpayroll, procedures will be enhanced to ensure proper allocation of nonpayroll costs to federal grants. Allocations will be reviewed and monitored on a monthly and quarterly basis to prevent misallocation and ensure compliance with the Uniform Guidance. Personnel responsible for implementation: Executive Director Christy Zamani and Beaulieu Accountancy Corporation. Date of implementation: August 5, 2025
Federal Program Information: Assistance Listing Number: 93.959 Federal Program Title: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004383-W2, PH-004383-W1 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Assistance Listing Number: 93.531 Federal Program Title: Community Transformation Grants and National Dissemination and Support for Community Transformation Grants Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004921 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria: Per the Uniform Guidance, 2 CFR §200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the actual work performed. Budget estimates may be used for interim purposes, but must be supported by contemporaneous documentation, reconciled to actual time worked, and adjusted as necessary. Additionally, 2 CFR §200.403(d) requires that costs be allocated to federal awards in accordance with the relative benefits received. The OMB Compliance Supplement (Part 6 – Internal Control and Part 3 – Compliance Requirements) reinforces that payroll and nonpayroll costs must be supported by reliable records and allocated using reasonable and consistent methodologies. Condition: During the testing of payroll costs, we noted that for Federal Assistance Listings 93.959 and 93.531, payroll charges in 4 out of 40 samples and 2 out of 11 samples, respectively, were based on budgeted rates rather than actual hours worked. Supporting documentation (e.g., timesheets or equivalent records) was not used to substantiate the final charges, and adjustments to actual time and effort were not made. For nonpayroll costs, we identified that in 3 out of 40 samples (93.959) and 5 out of 18 samples (93.531), costs were not allocated using a consistent and reasonable basis across all benefiting programs. Instead, the Organization either charged costs by maximizing the allowable budget under each program or have inadvertently used an incorrect basis due to oversight. Cause: The deficiencies occurred because the Organization’s internal controls were not sufficiently designed or implemented to ensure compliance with Uniform Guidance requirements. Specifically, payroll costs were charged to federal awards based on budget estimates rather than actual time and effort supported by records such as timesheets, and nonpayroll costs were either maximized to the budget or were allocated using an incorrect basis. These control gaps in review and documentation resulted in costs being charged to federal programs in a manner inconsistent with Allowable Costs/Cost Principles. Effect: As a result of these deficiencies, federal program expenditures reported to the awarding agency were misstated. Our testing identified questioned costs across both programs, consisting of payroll and nonpayroll overallocations. These represent unallowable costs under Uniform Guidance and may be subject to disallowance. Inaccurate cost allocations increase the risk of noncompliance with federal requirements, could lead to repayment of disallowed costs, and may negatively affect future federal funding decisions. Questioned Costs: Known and extrapolated costs for payroll and nonpayroll costs for Federal Assistance Listings 93.959 and 93.531 are summarized below. These amounts represent the overallocation to the programs, representing unallowable costs under Uniform Guidance. Recommendation: We recommend that the Organization strengthen its internal controls over payroll and nonpayroll cost allocations by requiring time and effort records to support all payroll charges to federal awards, ensuring nonpayroll costs are allocated using documented and equitable methodologies, and performing regular reconciliations of budgeted amounts to actual costs. In addition, staff responsible for preparing and reviewing cost allocations should receive training on Uniform Guidance requirements to ensure accuracy, compliance, and consistency across all federal programs. Views of responsible officials and planned corrective actions: For payroll, procedures will be implemented to ensure that payroll costs allocated to federal grants are supported by actual time. For nonpayroll, procedures will be enhanced to ensure proper allocation of nonpayroll costs to federal grants. Allocations will be reviewed and monitored on a monthly and quarterly basis to prevent misallocation and ensure compliance with the Uniform Guidance. Personnel responsible for implementation: Executive Director Christy Zamani and Beaulieu Accountancy Corporation. Date of implementation: August 5, 2025
Federal Program Information: Assistance Listing Number: 93.959 Federal Program Title: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004383-W2, PH-004383-W1 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Assistance Listing Number: 93.531 Federal Program Title: Community Transformation Grants and National Dissemination and Support for Community Transformation Grants Federal Agency: U.S. Department of Health and Human Services Passed Through Entity: County of Los Angeles Public Health Federal Award Number: PH-004921 Federal Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria: Per the Uniform Guidance, 2 CFR §200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the actual work performed. Budget estimates may be used for interim purposes, but must be supported by contemporaneous documentation, reconciled to actual time worked, and adjusted as necessary. Additionally, 2 CFR §200.403(d) requires that costs be allocated to federal awards in accordance with the relative benefits received. The OMB Compliance Supplement (Part 6 – Internal Control and Part 3 – Compliance Requirements) reinforces that payroll and nonpayroll costs must be supported by reliable records and allocated using reasonable and consistent methodologies. Condition: During the testing of payroll costs, we noted that for Federal Assistance Listings 93.959 and 93.531, payroll charges in 4 out of 40 samples and 2 out of 11 samples, respectively, were based on budgeted rates rather than actual hours worked. Supporting documentation (e.g., timesheets or equivalent records) was not used to substantiate the final charges, and adjustments to actual time and effort were not made. For nonpayroll costs, we identified that in 3 out of 40 samples (93.959) and 5 out of 18 samples (93.531), costs were not allocated using a consistent and reasonable basis across all benefiting programs. Instead, the Organization either charged costs by maximizing the allowable budget under each program or have inadvertently used an incorrect basis due to oversight. Cause: The deficiencies occurred because the Organization’s internal controls were not sufficiently designed or implemented to ensure compliance with Uniform Guidance requirements. Specifically, payroll costs were charged to federal awards based on budget estimates rather than actual time and effort supported by records such as timesheets, and nonpayroll costs were either maximized to the budget or were allocated using an incorrect basis. These control gaps in review and documentation resulted in costs being charged to federal programs in a manner inconsistent with Allowable Costs/Cost Principles. Effect: As a result of these deficiencies, federal program expenditures reported to the awarding agency were misstated. Our testing identified questioned costs across both programs, consisting of payroll and nonpayroll overallocations. These represent unallowable costs under Uniform Guidance and may be subject to disallowance. Inaccurate cost allocations increase the risk of noncompliance with federal requirements, could lead to repayment of disallowed costs, and may negatively affect future federal funding decisions. Questioned Costs: Known and extrapolated costs for payroll and nonpayroll costs for Federal Assistance Listings 93.959 and 93.531 are summarized below. These amounts represent the overallocation to the programs, representing unallowable costs under Uniform Guidance. Recommendation: We recommend that the Organization strengthen its internal controls over payroll and nonpayroll cost allocations by requiring time and effort records to support all payroll charges to federal awards, ensuring nonpayroll costs are allocated using documented and equitable methodologies, and performing regular reconciliations of budgeted amounts to actual costs. In addition, staff responsible for preparing and reviewing cost allocations should receive training on Uniform Guidance requirements to ensure accuracy, compliance, and consistency across all federal programs. Views of responsible officials and planned corrective actions: For payroll, procedures will be implemented to ensure that payroll costs allocated to federal grants are supported by actual time. For nonpayroll, procedures will be enhanced to ensure proper allocation of nonpayroll costs to federal grants. Allocations will be reviewed and monitored on a monthly and quarterly basis to prevent misallocation and ensure compliance with the Uniform Guidance. Personnel responsible for implementation: Executive Director Christy Zamani and Beaulieu Accountancy Corporation. Date of implementation: August 5, 2025
Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.
Type of Finding: Significant Internal Control over Compliance Compliance Requirement: Allowable Costs Criteria: The program requires the Center to request actual time worked by qualified employees when requesting reimbursement of funds from the City of San Antonio, as per 2 CFR §200.430(g)(vii). Condition: It was noted the supporting documentation submitted for reimbursement was calculated using budgeted percentages of wages for qualified employees instead of actual time worked. Cause: No procedures are in place to review the supporting documentation submitted for reimbursement was for actual time worked by qualified employees. Effect: Not using actual costs incurred when requesting reimbursement under this program can lead to reimbursement overstatements and non-compliance with the program. Recommendation: We recommend the Center report the reimbursement overstatement to City of San Antonio and correct the error. We recommend the Center develop procedures to review that supporting documentation submitted for reimbursement was for actual time worked. This review should be performed by personnel familiar with the program requirements. Views of Responsible Officials: Management agrees with the finding and will work with the City of San Antonio to correct the issue, and develop review procedures to respond to the finding.
Type of Finding: Significant Internal Control over Compliance Compliance Requirement: Allowable Costs Criteria: The program requires the Center to request actual time worked by qualified employees when requesting reimbursement of funds from the City of San Antonio, as per 2 CFR §200.430(g)(vii). Condition: It was noted the supporting documentation submitted for reimbursement was calculated using budgeted percentages of wages for qualified employees instead of actual time worked. Cause: No procedures are in place to review the supporting documentation submitted for reimbursement was for actual time worked by qualified employees. Effect: Not using actual costs incurred when requesting reimbursement under this program can lead to reimbursement overstatements and non-compliance with the program. Recommendation: We recommend the Center report the reimbursement overstatement to City of San Antonio and correct the error. We recommend the Center develop procedures to review that supporting documentation submitted for reimbursement was for actual time worked. This review should be performed by personnel familiar with the program requirements. Views of Responsible Officials: Management agrees with the finding and will work with the City of San Antonio to correct the issue, and develop review procedures to respond to the finding.
2024-003 Lack of Documentation to Support Distribution of Wages (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Special Education Cluster Assistance Listing Number(s): 84.027, 84.173, 84.027X, 84.173X Passed-through Identification: 20221035, 20221036, 20230212, 2024188, 20240189, 20240190, 20240191, 20240199, 20240308 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the School Administrative Unit, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to the federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) 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 ward or a federal award and non-Federal award. Condition: During current year testing, it was noted that the School Administrative Unit did not maintain semi-annual certifications for employees whose salaries were charged in whole or in part to federal programs for the second half of the fiscal year. Cause: The absence of certifications appears to be the result of oversight in the School Administrative Unit’s year-end grant compliance procedures. Specifically, management did not have an established monitoring process to ensure that semi-annual certifications were completed and retained for the full fiscal year. Effect: Without proper semi-annual certifications, the School Administrative Unit cannot fully demonstrate that salaries charged to federal programs were based on actual work performed for those programs. This creates the risk of questioned costs under the Uniform Guidance and may jeopardize the allowability of a portion of payroll expenditures charged to federal awards. Questioned Costs: $355,027 Identification as Repeat Finding: As identified in Schedule III, Summary Schedule of Prior Audit Findings, this is a repeat of finding 2023-002. Recommendation: We recommend the School Administrative Unit strengthen its grant compliance procedures by implementing a process to ensure that all required semi-annual certifications are completed timely and retained for each reporting period. This may include assigning responsibility to a specific individual for collecting certifications, establishing reminders at fiscal mid-year and year-end, and periodically reviewing files to confirm compliance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Finding 2024-003: Improve Controls and Document Retention Over Allowable Costs Federal Program Information Federal Agency: Department of Education Award Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Award Year: 2024 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non-Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.027 and 84.173 Special Education Cluster $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: See corrective action plan.
2024-001 Payroll Allocations Federal Program - U.S. Department of Education – Education Stabilization Fund (ALN 84.425D) Federal Award Number and Year - S425E210046 – FY24 Criteria - Per 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, are supported by a system of internal control, and must reasonably reflect the total activity for which the employee is compensated. Allocations must be made based on actual, not budgeted, time unless subsequently adjusted. Condition - During testing of payroll expenses charged to the ESSER grant, we identified instances where employee time reporting did not agree to the payroll costs allocated and charged to ESSER funding. In 2 out of 25 payroll transactions tested, totaling $6,286 in ESSER payroll charges, employee time reporting did not agree to the amount charged. Cause - The payroll allocation worksheet used to create the postings in the accounting system for payroll transactions was not updated for changes in employee responsibilities. Effect - The Organization charged payroll costs to the ESSER grant for time and effort not spent on the grant initiatives. Questioned Costs - $6,286 Context - Of a sample of 25 payroll transactions tested, 2 included variances between employee time reporting and payroll postings. The total ESSER payroll tested was $61,897, with total ESSER payroll expenditures of approximately $873,128 during the fiscal year. Identification as a Repeat Finding - No, this is a new finding in FY24. Recommendation - We recommend the Organization update the payroll allocation worksheet for changes in employee time and effort reporting on a regular basis with a frequency no less than quarterly. Payroll allocations to federal programs should be based on actual time worked on the program and time and effort reporting should agree to the amount charged. Views of Responsible Officials - we agree with the finding and determined it was due to an oversight by the employee on their time and effort reporting to not reflect an updated allocation based on a review of the job description and work completed by management. All work items performed by the employee would have been eligible and allowable under the grant contract.
Agency: U.S. Department of Health and Human Services Federal Assistance Listing Number: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance. Criteria: In accordance with 2 CFR §200.430(i) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), compensation for personal services charged to federal awards must be based on records that accurately reflect the work performed. When budget estimates are used for interim accounting purposes, they must: produce reasonable approximations of the activity actually performed, be reconciled to actual effort on a regular basis, and be adjusted in a timely manner to reflect significant changes in work activity. Documentation may include timesheets, effort certifications, payroll distribution reports, and other personnel activity records, and must be reviewed and approved by authorized personnel. Condition and Context: The Organization did not maintain documentation evidencing a hindsight review of employee working hours to verify alignment between actual hours worked and budgeted hours. This oversight was noted in instances where payroll costs for individual employees were allocated across multiple federal programs. While a time and effort certification was lacking for the items included in our sample, there was evidence of work performed on the grants and the amounts allocated aligned closely to the budget. Questioned Costs: We were unable to quantify an amount of questioned costs. While a time and effort certification was lacking for the items included in our sample, there was evidence of work performed on the grants and the amounts allocated aligned closely to the budget. Therefore, we were unable to quantify the amount of questioned costs. Cause: The Organization has not established or enforced formal policies and procedures requiring the documentation of time and effort for employees. Effect: The lack of documentation of hindsight review increases the risk of inaccurate payroll cost allocations and potential noncompliance with federal grant requirements. Recommendation: The Organization should update its policies and procedures to require and document a formal hindsight review of employee working hours. This review should verify that actual hours worked align with budgeted hours, particularly in cases where payroll costs are allocated across multiple federal programs. The updated procedures should include clear guidelines for conducting and retaining evidence of such reviews to support accurate cost allocations and ensure compliance with federal grant requirements.
Finding 2024-002: Improper Controls over Personnel Expenses Federal Agency: U.S. Department of Treasury Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $1,119,206 Questioned Costs: None Criteria: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure personnel activity reports are approved. Condition: A KHSU supervisor did not properly document approval for one employee’s personnel activity reports. Cause: KHSU officials stated that this issue was an isolated incident resulting from an unintentional oversight at multiple levels of approval. While established procedures generally ensure proper documentation of personnel activity reports, in this case, the required documentation was inadvertently missed during the review and approval process. Effect: If employee’s personnel activity reports are not properly reviewed and approved, KHSU could submit unallowable costs for the program. Questioned Costs: None Context: Of the 8 employee personnel activity reports sampled, one report did not contain the proper approval by a KHSU supervisor. Repeat Finding: No. Recommendation: We recommend KHSU strengthen internal controls around the approval of personnel activity reports to confirm that a reasonable person can confirm the control occurred. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Finding 2024-002: Improper Controls over Personnel Expenses Federal Agency: U.S. Department of Treasury Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $1,119,206 Questioned Costs: None Criteria: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure personnel activity reports are approved. Condition: A KHSU supervisor did not properly document approval for one employee’s personnel activity reports. Cause: KHSU officials stated that this issue was an isolated incident resulting from an unintentional oversight at multiple levels of approval. While established procedures generally ensure proper documentation of personnel activity reports, in this case, the required documentation was inadvertently missed during the review and approval process. Effect: If employee’s personnel activity reports are not properly reviewed and approved, KHSU could submit unallowable costs for the program. Questioned Costs: None Context: Of the 8 employee personnel activity reports sampled, one report did not contain the proper approval by a KHSU supervisor. Repeat Finding: No. Recommendation: We recommend KHSU strengthen internal controls around the approval of personnel activity reports to confirm that a reasonable person can confirm the control occurred. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Period of Performance – Federal: 45 CFR 75.309. State: 2 CFR 200.430. Condition – Costs charged to the grant award were incurred prior to the start of the period of performance. Questioned Costs – Federal: $103,466. State: $5,195. Questioned costs were determined by identifying salaries and wages incurred prior to the beginning of the period of performance based on payroll periods and pay dates. Questioned costs by federal or state award identification number are: • Assistance Listing No. 93.527 Award No. 6 H80CS00751 – $103,466 • Agreement No. 435100-G24-3919588107-90 – $5,195 Context – Salaries and wages from the first pay period paid during the period of performance was charged to the federal and state awards. For Award No. 6 H80CS00751 within Health Center Program Cluster (HCP), payroll paid on April 7, 2023, was charged to the federal award, while 100% of payroll costs were incurred as of March 31, 2023. For Agreement No. 435100-G24-3919588107-90 within Wisconsin Department of Health Community Health Center Program (CHCG), payroll paid on June 14, 2023, was charged to the state award, while 50% of payroll costs were incurred as of June 30, 2023. Effect – The Organization charged salaries and wages incurred prior to the beginning of the period of performance in both HCP and CHCG. Cause – Salaries and wages are charged to federal and state awards based on payroll documentation summarized monthly based on pay date rather than accrual-based salary and wage expense. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should implement cut-off procedures to ensure grant expenditures are captured on the accrual-basis consistent with period of performance compliance requirements and generally accepted accounting principles. To more easily accomplish this, the Organization should identify allowable salaries and wages by payroll period rather than from payroll data summarized monthly by pay date. Views of responsible officials and planned corrective actions – Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of noncompliance (such as cash management). Although the initial support provided to auditors contained instances of expenditures incurred prior to the beginning of the period of performance, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes for cut-off procedures related to grant expenditures. We will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff by lining up grant expenditures with pay periods instead of monthly allocations. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Period of Performance – Federal: 45 CFR 75.309. State: 2 CFR 200.430. Condition – Costs charged to the grant award were incurred prior to the start of the period of performance. Questioned Costs – Federal: $103,466. State: $5,195. Questioned costs were determined by identifying salaries and wages incurred prior to the beginning of the period of performance based on payroll periods and pay dates. Questioned costs by federal or state award identification number are: • Assistance Listing No. 93.527 Award No. 6 H80CS00751 – $103,466 • Agreement No. 435100-G24-3919588107-90 – $5,195 Context – Salaries and wages from the first pay period paid during the period of performance was charged to the federal and state awards. For Award No. 6 H80CS00751 within Health Center Program Cluster (HCP), payroll paid on April 7, 2023, was charged to the federal award, while 100% of payroll costs were incurred as of March 31, 2023. For Agreement No. 435100-G24-3919588107-90 within Wisconsin Department of Health Community Health Center Program (CHCG), payroll paid on June 14, 2023, was charged to the state award, while 50% of payroll costs were incurred as of June 30, 2023. Effect – The Organization charged salaries and wages incurred prior to the beginning of the period of performance in both HCP and CHCG. Cause – Salaries and wages are charged to federal and state awards based on payroll documentation summarized monthly based on pay date rather than accrual-based salary and wage expense. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should implement cut-off procedures to ensure grant expenditures are captured on the accrual-basis consistent with period of performance compliance requirements and generally accepted accounting principles. To more easily accomplish this, the Organization should identify allowable salaries and wages by payroll period rather than from payroll data summarized monthly by pay date. Views of responsible officials and planned corrective actions – Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of noncompliance (such as cash management). Although the initial support provided to auditors contained instances of expenditures incurred prior to the beginning of the period of performance, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes for cut-off procedures related to grant expenditures. We will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff by lining up grant expenditures with pay periods instead of monthly allocations. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet. While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. Payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 13 out of the 19 selected worklogs (68%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 7 and 102 working days (not including weekends) following the end of the pay period. Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
Condition: For 3 out of 25 selected transactions, management did not properly update the Full Time Equivalent (FTE) allocation tables, resulting in an overcharge of personnel costs to its Federal programs. Criteria: In accordance with 2 CFR §200.303: 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. In accordance with 2 CFR 200.430: (i) 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 both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: Maryland Legal Aid did not have controls in place to detect errors in the FTE allocation tables that were used to allocate personnel costs to its Federal programs. Effect: Unallowed payroll costs could be charged to Federal grants. Questioned Costs: Unknown. Recommendation: We recommend Maryland Legal Aid perform a detailed review of the FTE allocations used to allocate personnel costs to its Federal programs. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plan.
2023-003: Allowable costs/cost principles – Compensation Cluster: Research and Development Sponsoring Agency: U.S. Department of Justice, Department of Health and Human Services, and U.S. Department of Homeland Security Award Names: 2021 DOJ NIJ Heat Flux Through Walls, 2021 National Institute of Health Award, 2022 National Institute of Health Award, 2019 DHS Fire Prevention and Safety (FP&S), and 2018 DHS Assistance to Firefighters Grant (Subaward) Award Numbers: 15PNIJ-21-GG-04167-RESS, 7R56DE029950-02, 1R56DE031814-01, EMW-2019-FP-00770, and EMW-2018-FP-00482 Assistance Listing Titles: National Institute of Justice Research, Evaluation, and Development Project Grants, Oral Diseases and Disorders Research, Assistance to Firefighters Grant Assistance Listing Numbers: 16.560, 93.121, and 97.044 Pass-through entity: The Board of Trustees of the University of Illinois (for grant # EMW-2018-FP-00482) Criteria According to the Code of Federal Regulation Standard 2 CFR 200.430(i)(1)(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 The Company charges compensation costs to federal awards based on actual hours incurred, however, for certain awards, the hourly rate used to charge the federal award is based on midpoint of the labor rate range by employee type (versus the actual compensation rate for a given employee). No formal review was performed over the budgeted labor rates used to determine if any adjustments to actual cost were needed for each award. Through our testing of 13 compensation selections totaling $47,724, we identified eight selections totaling $33,240 where the compensation rate used was based on budgeted labor rate. When assessing these further with management, the impact to the awards for our selections was the Company could have charged an additional $4,287 to the awards. Cause The Company was not aware that a control should have been in place to true up labor charges based on a budgeted rate to actual labor rates. Effect The lack of a formal process for review over the budgeted rate used in calculating the allowable compensation could result in amounts charged to federal awards that are not accurate. Questioned Costs Based on the audit results, there was a net amount of $4,287 of additional labor costs that could have been charged to certain federal awards. Recommendation We recommend the Company formalize the review required for the budget labor rates used in calculating charges to federal awards. Management's Views and Corrective Action Plan Management’s views and corrective action plan are included at the end of this report after the summary of status of prior audit finding.
2023-003: Allowable costs/cost principles – Compensation Cluster: Research and Development Sponsoring Agency: U.S. Department of Justice, Department of Health and Human Services, and U.S. Department of Homeland Security Award Names: 2021 DOJ NIJ Heat Flux Through Walls, 2021 National Institute of Health Award, 2022 National Institute of Health Award, 2019 DHS Fire Prevention and Safety (FP&S), and 2018 DHS Assistance to Firefighters Grant (Subaward) Award Numbers: 15PNIJ-21-GG-04167-RESS, 7R56DE029950-02, 1R56DE031814-01, EMW-2019-FP-00770, and EMW-2018-FP-00482 Assistance Listing Titles: National Institute of Justice Research, Evaluation, and Development Project Grants, Oral Diseases and Disorders Research, Assistance to Firefighters Grant Assistance Listing Numbers: 16.560, 93.121, and 97.044 Pass-through entity: The Board of Trustees of the University of Illinois (for grant # EMW-2018-FP-00482) Criteria According to the Code of Federal Regulation Standard 2 CFR 200.430(i)(1)(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 The Company charges compensation costs to federal awards based on actual hours incurred, however, for certain awards, the hourly rate used to charge the federal award is based on midpoint of the labor rate range by employee type (versus the actual compensation rate for a given employee). No formal review was performed over the budgeted labor rates used to determine if any adjustments to actual cost were needed for each award. Through our testing of 13 compensation selections totaling $47,724, we identified eight selections totaling $33,240 where the compensation rate used was based on budgeted labor rate. When assessing these further with management, the impact to the awards for our selections was the Company could have charged an additional $4,287 to the awards. Cause The Company was not aware that a control should have been in place to true up labor charges based on a budgeted rate to actual labor rates. Effect The lack of a formal process for review over the budgeted rate used in calculating the allowable compensation could result in amounts charged to federal awards that are not accurate. Questioned Costs Based on the audit results, there was a net amount of $4,287 of additional labor costs that could have been charged to certain federal awards. Recommendation We recommend the Company formalize the review required for the budget labor rates used in calculating charges to federal awards. Management's Views and Corrective Action Plan Management’s views and corrective action plan are included at the end of this report after the summary of status of prior audit finding.
2023-003: Allowable costs/cost principles – Compensation Cluster: Research and Development Sponsoring Agency: U.S. Department of Justice, Department of Health and Human Services, and U.S. Department of Homeland Security Award Names: 2021 DOJ NIJ Heat Flux Through Walls, 2021 National Institute of Health Award, 2022 National Institute of Health Award, 2019 DHS Fire Prevention and Safety (FP&S), and 2018 DHS Assistance to Firefighters Grant (Subaward) Award Numbers: 15PNIJ-21-GG-04167-RESS, 7R56DE029950-02, 1R56DE031814-01, EMW-2019-FP-00770, and EMW-2018-FP-00482 Assistance Listing Titles: National Institute of Justice Research, Evaluation, and Development Project Grants, Oral Diseases and Disorders Research, Assistance to Firefighters Grant Assistance Listing Numbers: 16.560, 93.121, and 97.044 Pass-through entity: The Board of Trustees of the University of Illinois (for grant # EMW-2018-FP-00482) Criteria According to the Code of Federal Regulation Standard 2 CFR 200.430(i)(1)(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 The Company charges compensation costs to federal awards based on actual hours incurred, however, for certain awards, the hourly rate used to charge the federal award is based on midpoint of the labor rate range by employee type (versus the actual compensation rate for a given employee). No formal review was performed over the budgeted labor rates used to determine if any adjustments to actual cost were needed for each award. Through our testing of 13 compensation selections totaling $47,724, we identified eight selections totaling $33,240 where the compensation rate used was based on budgeted labor rate. When assessing these further with management, the impact to the awards for our selections was the Company could have charged an additional $4,287 to the awards. Cause The Company was not aware that a control should have been in place to true up labor charges based on a budgeted rate to actual labor rates. Effect The lack of a formal process for review over the budgeted rate used in calculating the allowable compensation could result in amounts charged to federal awards that are not accurate. Questioned Costs Based on the audit results, there was a net amount of $4,287 of additional labor costs that could have been charged to certain federal awards. Recommendation We recommend the Company formalize the review required for the budget labor rates used in calculating charges to federal awards. Management's Views and Corrective Action Plan Management’s views and corrective action plan are included at the end of this report after the summary of status of prior audit finding.
2023-003: Allowable costs/cost principles – Compensation Cluster: Research and Development Sponsoring Agency: U.S. Department of Justice, Department of Health and Human Services, and U.S. Department of Homeland Security Award Names: 2021 DOJ NIJ Heat Flux Through Walls, 2021 National Institute of Health Award, 2022 National Institute of Health Award, 2019 DHS Fire Prevention and Safety (FP&S), and 2018 DHS Assistance to Firefighters Grant (Subaward) Award Numbers: 15PNIJ-21-GG-04167-RESS, 7R56DE029950-02, 1R56DE031814-01, EMW-2019-FP-00770, and EMW-2018-FP-00482 Assistance Listing Titles: National Institute of Justice Research, Evaluation, and Development Project Grants, Oral Diseases and Disorders Research, Assistance to Firefighters Grant Assistance Listing Numbers: 16.560, 93.121, and 97.044 Pass-through entity: The Board of Trustees of the University of Illinois (for grant # EMW-2018-FP-00482) Criteria According to the Code of Federal Regulation Standard 2 CFR 200.430(i)(1)(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 The Company charges compensation costs to federal awards based on actual hours incurred, however, for certain awards, the hourly rate used to charge the federal award is based on midpoint of the labor rate range by employee type (versus the actual compensation rate for a given employee). No formal review was performed over the budgeted labor rates used to determine if any adjustments to actual cost were needed for each award. Through our testing of 13 compensation selections totaling $47,724, we identified eight selections totaling $33,240 where the compensation rate used was based on budgeted labor rate. When assessing these further with management, the impact to the awards for our selections was the Company could have charged an additional $4,287 to the awards. Cause The Company was not aware that a control should have been in place to true up labor charges based on a budgeted rate to actual labor rates. Effect The lack of a formal process for review over the budgeted rate used in calculating the allowable compensation could result in amounts charged to federal awards that are not accurate. Questioned Costs Based on the audit results, there was a net amount of $4,287 of additional labor costs that could have been charged to certain federal awards. Recommendation We recommend the Company formalize the review required for the budget labor rates used in calculating charges to federal awards. Management's Views and Corrective Action Plan Management’s views and corrective action plan are included at the end of this report after the summary of status of prior audit finding.