Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Program Titles – Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing No. – 93.243 Federal Agencies – U.S. Department of Health and Human Services Federal Award Numbers – S23-SM84816-027 Grant Award Periods – April 1, 2023 – September 29, 2023 Compliance Requirements – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: Costs of compensation are allowable to the extent that they satisfy the specific requirements of 2 CFR 200.430, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with entity’s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported (documented) as provided in 2 CFR 200.430 (i), when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other things, these records must: • Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities. – 2 CFR 200.430(i)(1)(iii) • Comply with the established accounting policies and practices of the non-federal entity. – 2 CFR 200.430(i)(1)(v) • 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. – 2 CFR 200.430(i)(1)(vii)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: – The system for establishing the estimates produces reasonable approximations of the activity actually performed; – 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 – 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. Conditions Found: Compensation charges were charged to ALN 93.243, and included $828,602 of salaries and fringes that were allocated to the grant based on budget estimates to time spent by the employees. Boys Town has policies that require a certification process to affirm after-the-fact the allocation based on budget estimates were appropriate or require adjustment in the accounting records. Boys Town policies require effort reports for monthly, quarterly, and annual time periods. Completion and certification must occur no later than 60 days from the end of the time period that is being certified. On January 1, 2023, Boys Town implemented a new enterprise resource planning system, Workday, which included human resources and payroll processing. Workday has an effort reporting business process built into its functionality. However, since the implementation of Workday, no certifications have been performed. As part of monthly invoicing to grantor under ALN 93.243, details of employees and their percentage of time allocated is included in the invoicing package. This monthly invoice is reviewed by program manager. Questioned Cost: Question costs is not determinable. Cause and Effect: In discussing these conditions with Boys Town management, there were issues with the system implementation that required re-allocation of payroll that were not finalized until March 2024. This led to delays in initiating the effort certification process in Workday to ensure accurate information could be certified. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend Boys Town to enhance its internal control process to ensure Boys Town has effective internal controls in place to ensure Boys Town is complying with internal policies and obtaining after-the-fact affirmations for compensation allocated to federal awards. View of Responsible Official: We agree with the conclusions in the finding. Management has already taken corrective action to retroactively obtain certifications for time and effort for the year ended December 31, 2023 and through September 30, 2024. In addition, a process has been implemented to allow certifications to occur in accordance with our policies for the remainder of the fiscal year.
Federal Award Findings and Questioned Costs Finding No. 2023-001: Allowable Cost (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.224 Health Center Program Cluster ALN 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to the work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.224 Health Center Program Cluster and 40 payroll costs charged to ALN 93.354 Public Health Emergency Response: Cooperative agreement for Emergency Response: Public Health Crisis Response. Time and effort reporting could not be located for any of the charges which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization changed payroll systems during the year and did not implement procedures to properly track time and effort under the new system. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: Unknown Repeat Finding: No Recommendation: Management should establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allowable costs which includes ensuring time and effort charges are based on records that accurately reflect the work performed. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.
Federal Award Findings and Questioned Costs Finding No. 2023-001: Allowable Cost (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.224 Health Center Program Cluster ALN 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to the work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.224 Health Center Program Cluster and 40 payroll costs charged to ALN 93.354 Public Health Emergency Response: Cooperative agreement for Emergency Response: Public Health Crisis Response. Time and effort reporting could not be located for any of the charges which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization changed payroll systems during the year and did not implement procedures to properly track time and effort under the new system. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: Unknown Repeat Finding: No Recommendation: Management should establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allowable costs which includes ensuring time and effort charges are based on records that accurately reflect the work performed. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.
Finding 2023-001 Material Weakness: Allowable Costs/Costs Principles – Compliance and Control Finding ALN 84.287 – Twenty-First Century Community Learning Centers Federal Agency: U.S. Department of Education Pass-Through Entity: Missouri Department of Education Fiscal Year: For the year ended December 31, 2023 Criteria or Specific Requirement: 2 CFR section 200.430(i)(1) requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition: We noted through procedures performed that allocated salaries and wages as well as related employee benefits and payroll taxes were based on an estimated percentage of time to be devoted to the grant-funded programs as opposed to actual hours worked, resulting in a potential over-allocation or under-allocation of expenditures. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of allocated versus actual hours work by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements related to allowable costs and allowable activities could go undetected as there is no review or true up process for actual hours worked related to the program. Questioned Costs: In a sample of 40 expenditures, total known question costs found totaled $46,571. Likely questioned costs exceed $25,000. Context: Of the sample of 40 individual costs charged to the grant, 12 were allocated salary costs and related employee benefits and payroll taxes of full-time, salaried employees. For these 12 payroll related items, allocated costs were based on the estimated percentage of time expected to be devoted by each employee to the grant-funded program. Unleashing Potential did not maintain documentation to support the actual time and effort of each employee charged to the grant. Identification as a Repeat Finding: 2022-001 Recommendation: For employees working on grant-funded programs, management should develop a time-keeping process to track and verify that the amount of time charged to the grant is accurate and based on the employee’s time spent working on the grant. Documented review and approval of this time allocation by the employee’s supervisor should be maintained. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the 21st Century program are reviewed by a competent individual, and those reviews will be documented.
Finding 2023-003 - Noncompliance and Significant Deficiency over Allowable Activities and Costs Criteria In accordance with 2 CFR 200.430(i)(1), the Organization is required to maintain documentation of personnel expenses that are “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.” Condition During testing of payroll transactions, we were unable to agree direct costs charged to the grant to the detail backup documentation retained. In addition, one individual, who was 100% funded by the grant, had costs in excess of 100% of compensated activities charged to the grant. Internal controls were not present or functioning to prevent excess costs from being allocated to the grant. Cause The Organization did not have appropriate internal controls in place over allowable costs and allowable activities which allowed for inaccuracies in payroll amounts claimed for reimbursement. Effect Payroll charges to the grant were unsupported. Questioned Costs Projected questioned costs were $5,073. Recommendations We recommend the Organization implement internal controls to ensure direct costs reported and reimbursed under the grant are accurate and allowable. Views of Responsible Officials We have increased personnel and have the support needed to implement our accounting policies.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Repeat Finding: No Condition: Management did not review and approve the time and effort allocation of employees working under Federal grants. Criteria: In accordance with 2 CFR §200.430, the non-Federal entity may compensate for personal services including all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. The costs of compensation are allowable to the extent that they satisfy the specific requirements of this part. Additionally, as defined in 2 CFR Ch. II (1-1-18 Edition) §200.430(g), for compensation to members of nonprofit organizations, trustees, directors, associates, officers, or the immediate families thereof, determination must be made that such compensation is reasonable for the actual personal services rendered rather than a distribution of earnings in excess of costs. This may include director’s and executive committee member’s fees, incentive awards, allowances for offsite pay, incentive pay, location allowances, hardship pay, and cost-of-living differentials. Cause: Management did not review and approve the time and effort allocation of employees working under federal grants. Effect: If the time and allocation efforts of employees working under federal grants were not reviewed and approved in compliance with Uniform Guidance, the Foundation would not identify the compensation allocation and billing to the federal grants for a reasonable amount. Questioned Costs: Unknown. Recommendation: We recommend that the Foundation review and approve the time and effort allocation of employees working under federal grants to ensure proper tracking and billing for compensation amount allowed per the federal award. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Information on the Major Federal Program: Federal agency: U.S. Department of Health and Human Services Pass-through entity: Council of Medical Specialty Societies Assistance listing number: 93.083 Assistance listing name: COVID-19 Prevention of Disease, Disability, and Death through Immunization and Control of Respiratory and Related Diseases Award number: 1NH231P922656-01-00 Award name: Improving adult immunization rates for COVID-19, influenza and routine adult vaccination through partnerships with medical subspecialty societies Award year: 9/30/2021 – 9/30/2026 Criteria – The Uniform Guidance in 2 CFR 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such charges should reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities. Condition – Payroll costs amounting to approximately $97,000 were over-allocated to the federal award for the year ended December 31, 2023 resulting from allocation of some payroll costs for hours not worked on the federal award. The federal award is a cost reimbursement grant and the over-allocation resulted in the federal award being charged more than the actual hours spent on the award. Reimbursement requests to the federal agency in 2024 were reduced by these over-allocated and unallowable costs of 2023. Cause – The non-compliance was due to inadequate internal controls over the allocation of payroll costs to federal awards. Specifically, the College did not have sufficient review processes in place to ensure that payroll costs were accurately allocated according to the work performed on the federal award. This discrepancy was identified by the College’s own controls during the year-end review of the Schedule, but after the costs had been over-allocated and billed to the cognizant agency. Corrective action was subsequently taken to adjust the amount charged and billed under the federal award in the following year by the over-allocated amount in 2023. Questioned Costs – There are approximately $97,000 of known questioned costs related to the items presented in the condition above. Context – The over-allocation of payroll costs was identified by the College during review of the Schedule after year end, which resulted in non-compliance with activities allowed or unallowed and allowable costs/cost principles. The prevalence of this finding is detailed in the condition section above. Effect – The over-allocation of payroll costs to federal awards may lead to improper use of federal funds. Repeat Finding – This is not a repeat finding. Recommendation – The College should strengthen its internal controls over the allocation of payroll costs to federal awards. This includes implementing a review process to ensure that payroll costs are accurately allocated based on the work performed and are supported by appropriate documentation. Additionally, the College should provide training to its personnel on the requirements of the Uniform Guidance related to allowable costs and cost principles. Views of Responsible Officials – Management acknowledges the finding and recommendation presented. Management will improve staff knowledge of Uniform Guidance through additional training on allowable costs and compliance. Payroll costs will be based on certified actual hours, verified by the Controller for accuracy. Quarterly reviews by the Technical and Internal Controls Accountant will ensure payroll costs match certified hours, maintaining compliance.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Medical Assistance Program, COVID-19 Block Grants for Prevention and Treatment of Substance Abuse ALN: 93.778, 93.959 Award period: July 1, 2022 – June 30, 2024 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, the 2 CFR Part 200.430 requires that charges to Federal awards for salaries and wages must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Employee benefits expenditures charged to the programs do not agree to supporting documentation, such as employee benefit provider premiums invoices. Additionally, the pay rate paid to an employee was different from their approved pay rate. Lastly, an employee received eight hours of birthday pay (as allowed under ABHS’s personnel policies) in two different pay periods. Context: Nine of 25 employee benefit expenditures tested did not agree with employee benefit provider premium invoices. One of 25 employees tested was paid at a rate different from their approved pay rate. One of 25 employees tested received eight hours of birthday pay in two different pay periods. Questioned Costs: $358 for the Medical Assistance Program and $0 for the COVID-19 Block Grants for Prevention and Treatment of Substance Abuse program. Cause: The employer portion of employee benefit premiums are preloaded into the accounting system each year to be allocated to the different business units/programs at ABHS. ABHS does not have a process in place to subsequently reconcile these expenditures to the employer benefits provider premium invoices and/or employee benefit election forms. There was also a lack of review of approved pay rates and leave requests during 2023. Effect: ABHS may not be able to demonstrate that the costs charged to federal programs are allowable. Auditor’s Recommendations: ABHS should implement a reconciliation process to ensure that employee benefit expenditures charged to federal programs agree with employee benefit provider premiums invoices and/or employee benefit election forms.41 Management’s Response: ABHS acknowledges the finding related to employer benefits. As a corrective measure, we have initiated a comprehensive review of our current systems and identified key areas that require immediate upgrades. With the adoption of these upgrades, ABHS will perform an interim review of the expenditures recorded in the accounting system compared to the invoices.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Medical Assistance Program, COVID-19 Block Grants for Prevention and Treatment of Substance Abuse ALN: 93.778, 93.959 Award period: July 1, 2022 – June 30, 2024 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, the 2 CFR Part 200.430 requires that charges to Federal awards for salaries and wages must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Employee benefits expenditures charged to the programs do not agree to supporting documentation, such as employee benefit provider premiums invoices. Additionally, the pay rate paid to an employee was different from their approved pay rate. Lastly, an employee received eight hours of birthday pay (as allowed under ABHS’s personnel policies) in two different pay periods. Context: Nine of 25 employee benefit expenditures tested did not agree with employee benefit provider premium invoices. One of 25 employees tested was paid at a rate different from their approved pay rate. One of 25 employees tested received eight hours of birthday pay in two different pay periods. Questioned Costs: $358 for the Medical Assistance Program and $0 for the COVID-19 Block Grants for Prevention and Treatment of Substance Abuse program. Cause: The employer portion of employee benefit premiums are preloaded into the accounting system each year to be allocated to the different business units/programs at ABHS. ABHS does not have a process in place to subsequently reconcile these expenditures to the employer benefits provider premium invoices and/or employee benefit election forms. There was also a lack of review of approved pay rates and leave requests during 2023. Effect: ABHS may not be able to demonstrate that the costs charged to federal programs are allowable. Auditor’s Recommendations: ABHS should implement a reconciliation process to ensure that employee benefit expenditures charged to federal programs agree with employee benefit provider premiums invoices and/or employee benefit election forms.41 Management’s Response: ABHS acknowledges the finding related to employer benefits. As a corrective measure, we have initiated a comprehensive review of our current systems and identified key areas that require immediate upgrades. With the adoption of these upgrades, ABHS will perform an interim review of the expenditures recorded in the accounting system compared to the invoices.
Finding 2023–002: Internal Controls over Allowable Activities and Costs Federal Department: U.S. Department of Treasury Pass-through Agencies: Cook County, Illinois and Women's Business Development Center COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, Federal Assistance Listing Number 21.027 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards for Financial and Program Management Section 200.303, Internal controls states “The non-Federal” entity must: (1) 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 terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (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…; (v) Comply with the established accounting policies and practices of the non-federal entity…; (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 adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Per Exhibit A, Section D – Program Administration and Process Overview of the Subrecipient Agreement for the American Rescue Plan Act – State and Local Fiscal Recovery Funds dated July 20, 2022 with Cook County, Illinois, SDA was required to perform certain eligibility verification of program participant. The agreement notes that the subrecipient (SDA) has discretion on how to verify participants eligibility but should define and consistently apply an intake policy that includes maintaining documentation on each beneficiary that supports their eligibility, such as signed self-attestation forms from beneficiaries, financial documents that demonstrate economic hardship, geographic data showing that a program participant operates in a region that experienced disproportionate pandemic harm. SDA utilized an eligibility form (formerly panel review form) to document compliance with this requirement. Condition During the current audit period, SDA did not maintain adequate controls over allowable activities and costs related to its federally funded program. Cause SDA implemented the fiscal policy in 2023, which improved data retention and management for grant reporting of federal programs. Due to inconsistency in staffing during 2023, however, some historical gaps in data were found that were unable to be corrected prior to or during the 2023 audit. In addition, with the implementation of SDA’s customized Salesforce data management system, some data was deleted or lost during the transition, resulting in incomplete or missing records. Effect The failure to maintain adequate supporting documentation to ensure all expenditures, including personnel costs, are accurate, reasonable and allowable is a violation of federal regulations. Also, not maintaining support for actual time spent by employees on the program could result in unallowed payroll costs being charged to the federally funded program. Questioned Costs We noted total questioned costs of $36,170. Context During our review of 40 expenditures (from a 547 population) and related payroll activities (from a population of 58 totaling $231,798), we noted the following: For 18 expenditures reviewed, we were not provided with the cost allocation schedule to support the actual charges to the federal program. Following our review of the total invoice amount, we did not note any costs that were deemed to be unallowed per the grantor(s) requirements and federal regulations. During our review of 10 payroll expense items, we noted that payroll expenses charged to the program were based on estimates instead of the actual time and effort of reporting, which totaled $36,170. We were provided with a listing of 244 clients served who were required to undergo an eligibility/intake review as specified in the grant agreement. We were not provided documentation, such as a completed eligibility form, to verify that the eligibility/intake review was performed for 21 of 25 clients served that were tested. It appears data was lost during the Salesforce (electronic system utilized to store eligibility data) system migration. Identification of Repeated Findings Repeated (Prior Finding No. 2022-002). Recommendation We recommend that SDA implement procedures to ensure all expenditures, including personnel costs, are properly reviewed and supporting documentation maintained in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action SDA agrees with the finding and recommendation. See SDA’s Corrective Action Plan on pages 40 – 44.
Finding 2023–002: Internal Controls over Allowable Activities and Costs Federal Department: U.S. Department of Treasury Pass-through Agencies: Cook County, Illinois and Women's Business Development Center COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, Federal Assistance Listing Number 21.027 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards for Financial and Program Management Section 200.303, Internal controls states “The non-Federal” entity must: (1) 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 terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (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…; (v) Comply with the established accounting policies and practices of the non-federal entity…; (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 adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Per Exhibit A, Section D – Program Administration and Process Overview of the Subrecipient Agreement for the American Rescue Plan Act – State and Local Fiscal Recovery Funds dated July 20, 2022 with Cook County, Illinois, SDA was required to perform certain eligibility verification of program participant. The agreement notes that the subrecipient (SDA) has discretion on how to verify participants eligibility but should define and consistently apply an intake policy that includes maintaining documentation on each beneficiary that supports their eligibility, such as signed self-attestation forms from beneficiaries, financial documents that demonstrate economic hardship, geographic data showing that a program participant operates in a region that experienced disproportionate pandemic harm. SDA utilized an eligibility form (formerly panel review form) to document compliance with this requirement. Condition During the current audit period, SDA did not maintain adequate controls over allowable activities and costs related to its federally funded program. Cause SDA implemented the fiscal policy in 2023, which improved data retention and management for grant reporting of federal programs. Due to inconsistency in staffing during 2023, however, some historical gaps in data were found that were unable to be corrected prior to or during the 2023 audit. In addition, with the implementation of SDA’s customized Salesforce data management system, some data was deleted or lost during the transition, resulting in incomplete or missing records. Effect The failure to maintain adequate supporting documentation to ensure all expenditures, including personnel costs, are accurate, reasonable and allowable is a violation of federal regulations. Also, not maintaining support for actual time spent by employees on the program could result in unallowed payroll costs being charged to the federally funded program. Questioned Costs We noted total questioned costs of $36,170. Context During our review of 40 expenditures (from a 547 population) and related payroll activities (from a population of 58 totaling $231,798), we noted the following: For 18 expenditures reviewed, we were not provided with the cost allocation schedule to support the actual charges to the federal program. Following our review of the total invoice amount, we did not note any costs that were deemed to be unallowed per the grantor(s) requirements and federal regulations. During our review of 10 payroll expense items, we noted that payroll expenses charged to the program were based on estimates instead of the actual time and effort of reporting, which totaled $36,170. We were provided with a listing of 244 clients served who were required to undergo an eligibility/intake review as specified in the grant agreement. We were not provided documentation, such as a completed eligibility form, to verify that the eligibility/intake review was performed for 21 of 25 clients served that were tested. It appears data was lost during the Salesforce (electronic system utilized to store eligibility data) system migration. Identification of Repeated Findings Repeated (Prior Finding No. 2022-002). Recommendation We recommend that SDA implement procedures to ensure all expenditures, including personnel costs, are properly reviewed and supporting documentation maintained in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action SDA agrees with the finding and recommendation. See SDA’s Corrective Action Plan on pages 40 – 44.
Criteria: 2 CFR 200.430(i) indicates costs must be based on records that accurately reflect the work performed to be considered allowable. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context: We selected 4 months of payroll expense charged to the grant for testing during the audit and noted that each month had at least one employee who did not have detailed time sheets or time studies to adequately support the hours charged to the grant. Our sample covered 7 employees over these 4 months and 3 of the employees tested did not have adequate support for the time charged. We tested a total of $33,351 of claimed payroll cost and identified known questioned costs of $3,770 which resulted in likely questioned costs of $5,308 using an error rate of 11% over total payroll claimed for 2023 of $46,955. Our sample was not considered to be a statistically valid sample. This finding is a repeat finding of 2022-002. Cause and Effect: The lack of adequate documentation to support time charged to the federal award combined with the finding 2023-003 resulted in material noncompliance to the referenced compliance requirements and to the program as a whole. Recommendation: We recommend the Association implement procedures for all employees who have payroll claimed under federal programs to prepare detailed timecards or time studies to support the distribution of each employee's compensation among specific activities, including the allocation of compensation to federal awards. These records should be reviewed by the employee's supervisor for accuracy. Views of Responsible Officials and Planned Corrective Actions: The Association agrees with the finding and plans to implement their corrective action during October 2024.
AL number and title: WIOA Cluster - 17.258, 17.259 and 17.278 Coronavirus State and Local Fiscal Recovery Funds - 21.027 VA Supportive Services for Veteran Families Program - 64.033 Refugee and Entrant Assistance State/Replacement Designee Administered Programs - 93.566 Federal award identification number and year: N/A Name of federal agency: U.S. Departments of Labor, Treasury, Veteran's Affairs and Health and Human Services Name of pass-through entity: State of California Employment Development Department; County of Los Angeles Workforce Development, Aging, and Community Services Department; City of Los Angeles Economic and Workforce Development Department; Catholic Charities of Los Angeles Repeat finding: No Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, organizations are permitted to use budgeted amounts to allocate time to Federal programs, as long as there is a process in place to true-up the costs on a regular basis. Condition: In general, JVS personnel prepare manual timesheets to record the actual time worked on the organization’s various programs. No process is currently in place to compare or revise the time if the budgeted time differs from the actual time. Cause: The organization lacked sufficient accounting resources to prepare these updates. Currently, the process would be very manual. Effect or potential effect: Hours charged to certain programs did not agree to the timesheets completed by employees and reviewed by their supervisors. Questioned cost: Estimated questioned costs related to variances in timesheets: Refugee Assistance programs - Known = $1,866, Projected = $24,944 WIOA programs - Known = $168, Projected = $58,485. Context: We tested a total of 114 timesheets and noted variances in 23. We also noted two instances where no timesheets were completed for administrative personnel. Recommendation: Management should institute a reconciliation and update process for the manual timecards. In addition, management should determine whether its electronic timekeeping systems can be reconfigured to allow employees to update their allocations as needed each pay period. View of Responsible Official: We agree with the finding. JVS has been evaluating how to fully address and resolve the issue. Remediation lies in modifying the current payroll platform (Paylocity) to facilitate employees ability to individually update their labor allocations electronically. JVS still does not have a sandbox testing environment to address system capabilities to achieve the objectives.
AL number and title: WIOA Cluster - 17.258, 17.259 and 17.278 Coronavirus State and Local Fiscal Recovery Funds - 21.027 VA Supportive Services for Veteran Families Program - 64.033 Refugee and Entrant Assistance State/Replacement Designee Administered Programs - 93.566 Federal award identification number and year: N/A Name of federal agency: U.S. Departments of Labor, Treasury, Veteran's Affairs and Health and Human Services Name of pass-through entity: State of California Employment Development Department; County of Los Angeles Workforce Development, Aging, and Community Services Department; City of Los Angeles Economic and Workforce Development Department; Catholic Charities of Los Angeles Repeat finding: No Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, organizations are permitted to use budgeted amounts to allocate time to Federal programs, as long as there is a process in place to true-up the costs on a regular basis. Condition: In general, JVS personnel prepare manual timesheets to record the actual time worked on the organization’s various programs. No process is currently in place to compare or revise the time if the budgeted time differs from the actual time. Cause: The organization lacked sufficient accounting resources to prepare these updates. Currently, the process would be very manual. Effect or potential effect: Hours charged to certain programs did not agree to the timesheets completed by employees and reviewed by their supervisors. Questioned cost: Estimated questioned costs related to variances in timesheets: Refugee Assistance programs - Known = $1,866, Projected = $24,944 WIOA programs - Known = $168, Projected = $58,485. Context: We tested a total of 114 timesheets and noted variances in 23. We also noted two instances where no timesheets were completed for administrative personnel. Recommendation: Management should institute a reconciliation and update process for the manual timecards. In addition, management should determine whether its electronic timekeeping systems can be reconfigured to allow employees to update their allocations as needed each pay period. View of Responsible Official: We agree with the finding. JVS has been evaluating how to fully address and resolve the issue. Remediation lies in modifying the current payroll platform (Paylocity) to facilitate employees ability to individually update their labor allocations electronically. JVS still does not have a sandbox testing environment to address system capabilities to achieve the objectives.
AL number and title: WIOA Cluster - 17.258, 17.259 and 17.278 Coronavirus State and Local Fiscal Recovery Funds - 21.027 VA Supportive Services for Veteran Families Program - 64.033 Refugee and Entrant Assistance State/Replacement Designee Administered Programs - 93.566 Federal award identification number and year: N/A Name of federal agency: U.S. Departments of Labor, Treasury, Veteran's Affairs and Health and Human Services Name of pass-through entity: State of California Employment Development Department; County of Los Angeles Workforce Development, Aging, and Community Services Department; City of Los Angeles Economic and Workforce Development Department; Catholic Charities of Los Angeles Repeat finding: No Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, organizations are permitted to use budgeted amounts to allocate time to Federal programs, as long as there is a process in place to true-up the costs on a regular basis. Condition: In general, JVS personnel prepare manual timesheets to record the actual time worked on the organization’s various programs. No process is currently in place to compare or revise the time if the budgeted time differs from the actual time. Cause: The organization lacked sufficient accounting resources to prepare these updates. Currently, the process would be very manual. Effect or potential effect: Hours charged to certain programs did not agree to the timesheets completed by employees and reviewed by their supervisors. Questioned cost: Estimated questioned costs related to variances in timesheets: Refugee Assistance programs - Known = $1,866, Projected = $24,944 WIOA programs - Known = $168, Projected = $58,485. Context: We tested a total of 114 timesheets and noted variances in 23. We also noted two instances where no timesheets were completed for administrative personnel. Recommendation: Management should institute a reconciliation and update process for the manual timecards. In addition, management should determine whether its electronic timekeeping systems can be reconfigured to allow employees to update their allocations as needed each pay period. View of Responsible Official: We agree with the finding. JVS has been evaluating how to fully address and resolve the issue. Remediation lies in modifying the current payroll platform (Paylocity) to facilitate employees ability to individually update their labor allocations electronically. JVS still does not have a sandbox testing environment to address system capabilities to achieve the objectives.
AL number and title: WIOA Cluster - 17.258, 17.259 and 17.278 Coronavirus State and Local Fiscal Recovery Funds - 21.027 VA Supportive Services for Veteran Families Program - 64.033 Refugee and Entrant Assistance State/Replacement Designee Administered Programs - 93.566 Federal award identification number and year: N/A Name of federal agency: U.S. Departments of Labor, Treasury, Veteran's Affairs and Health and Human Services Name of pass-through entity: State of California Employment Development Department; County of Los Angeles Workforce Development, Aging, and Community Services Department; City of Los Angeles Economic and Workforce Development Department; Catholic Charities of Los Angeles Repeat finding: No Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, organizations are permitted to use budgeted amounts to allocate time to Federal programs, as long as there is a process in place to true-up the costs on a regular basis. Condition: In general, JVS personnel prepare manual timesheets to record the actual time worked on the organization’s various programs. No process is currently in place to compare or revise the time if the budgeted time differs from the actual time. Cause: The organization lacked sufficient accounting resources to prepare these updates. Currently, the process would be very manual. Effect or potential effect: Hours charged to certain programs did not agree to the timesheets completed by employees and reviewed by their supervisors. Questioned cost: Estimated questioned costs related to variances in timesheets: Refugee Assistance programs - Known = $1,866, Projected = $24,944 WIOA programs - Known = $168, Projected = $58,485. Context: We tested a total of 114 timesheets and noted variances in 23. We also noted two instances where no timesheets were completed for administrative personnel. Recommendation: Management should institute a reconciliation and update process for the manual timecards. In addition, management should determine whether its electronic timekeeping systems can be reconfigured to allow employees to update their allocations as needed each pay period. View of Responsible Official: We agree with the finding. JVS has been evaluating how to fully address and resolve the issue. Remediation lies in modifying the current payroll platform (Paylocity) to facilitate employees ability to individually update their labor allocations electronically. JVS still does not have a sandbox testing environment to address system capabilities to achieve the objectives.
2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensationpersonal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Cause: The Organization used time records which did not clearly differentiate between the activities conducted and the hours worked to support compensation supported by each federal award and nonfederal awards. Potential Effect: Reimbursement for compensation under federal awards without time records, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2021 audit, finding #2021-002, related to the Crime Victim Assistance grant. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will modify procedures to reflect actual time worked by employee on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award.