2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds: • 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles; • 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs; • 2 CFR 200.318(c)(1) for employee conflicts of interest; • 2 CFR 200.318(c)(2) for organizational conflicts of interest; • 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals; • 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals. During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds: • 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles; • 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs; • 2 CFR 200.318(c)(1) for employee conflicts of interest; • 2 CFR 200.318(c)(2) for organizational conflicts of interest; • 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals; • 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals. During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds: • 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles; • 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs; • 2 CFR 200.318(c)(1) for employee conflicts of interest; • 2 CFR 200.318(c)(2) for organizational conflicts of interest; • 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals; • 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals. During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
CONDITION: Employee time and effort reports were not consistently completed, certified, and maintained in accordance with the grant requirements. The auditor's review of a sample of employee timesheets found discrepancies in how time was allocated and reported for federal projects versus the PALM’s internal records. CRITERIA: The PALM is required by federal grant guidelines, specifically 2 CFR 200.430, to maintain internal controls over all aspects of their federal awards. This includes accurate and consistent documentation of personnel activity reports, timesheets, and payroll distribution records to support the direct labor costs charged to federal awards. CAUSE: The PALM lacked a formal, documented policy and procedure for tracking, certifying, and approving employee time spent on grant-related activities. Insufficient training was provided to employees and supervisors regarding the specific documentation requirements for federal grants. This resulted in personnel recording their time using inconsistent methods, including estimations at the end of a pay period, which increased the risk of inaccurate billing. EFFECT: Inaccurate time allocation led to the questioning of $95,618 in costs charged to the federal award. Since the timekeeping records did not provide reliable assurance that employee compensation was accurately charged, a portion of the labor costs was unsupported. This finding exposes the PALM to the risk of having to repay the federal agency for unallowable costs and could impact future grant funding. RECOMMENDATION: We recommend that the PALM utilize a time management software which integrates with their payroll processing, to easily identify direct labor costs related to the federal program. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION: The PALM agrees with the finding, and started utilizing a new time management software in 2025 to prevent overbilling of direct labor costs. QUESTIONED COSTS: A total of $77,538 in salaries and $18,080 in benefits were calculated as questioned costs, based on annualized differences from testing.
Finding 2023-002, Timesheet – Timekeeping (Assistance Listing 93.567 and 93.576) Criteria: 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Condition and Context: The Organization’s current timesheet does not include the allocation of hours worked by program, neither the schedule provided that support employees’ payroll allocation agreed for 14 out of the 48 sampled selected. Cause: Internal controls over the accurate distribution of hours on the timesheets were not operating effectively or designed properly as well as the worksheets that support the payroll allocation. Effect: The timesheets or worksheets do not support the allocation of time charged to the programs. Identification as a repeat finding: No. Questioned costs: None. Recommendation: We recommend that the Organization strengthen its policies and procedures for the timekeeping and distribution of the employees’ hours in accordance with the requirements of the federal programs.
Finding 2023-002 – Internal Control over Compliance (Material Weakness) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Federal Award Identification Number: 43CAZ03215 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Material Weakness in internal control over compliance Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part 200.430(i) states “Cost must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition: Employee change of status forms are not consistently maintained in accordance with applicable requirements. Questioned Costs: None. Context: 10 Employee files that were selected for verification disclosed 3 instances where forms were not available for review. Cause: Employee change of status forms or offer letters were not maintained on file or available for review. Effect: Inability to review employee change of status forms or offer letters limits the ability to verify costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain compliance with allowable costs as required by 2 CFR 200.430. Repeat Finding: Yes Recommendation: Offer letters or employee change of status forms should be maintained on file. We recommend management implement a second layer of review of personnel files. Views of Responsible Official: Since the hiring of the Executive Director in March of 2023, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2023. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured. This includes hiring documentation and change of status forms for employees.
Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, charges to Federal awards for compensation must be supported by a system of internal control which provides reasonable assurance that costs are allocated appropriately and accurately. Per 2 CFR §200.403, allowable costs must be "necessary, reasonable, and adequately documented." Additionally, 2 CFR §200.302(b)(3) requires non-Federal entities to maintain records that sufficiently detail financial transactions to support Federal expenditures. Condition: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Certain employees charged to the grant did not prepare timesheets and a separate tracking system was used. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Cause: The Federal program was new to the organization and controls over the program had not been fully established. Turnover in the accounting department contributed to the lack of resources for tracking these costs. Effect or potential effect: Management provided documentation on personnel costs allocated to the program, but was unable to provide evidence of review. Lack of review increases the risk of unauthorized or unallowable costs being charged to the Federal award, potentially leading to questioned costs and noncompliance with Federal grant requirements. Context: This issue applied to less than 10% of the grant expenditures, $54,505 out of the $897,736 of total expenditures charged to the grant. Recommendation: Management should review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional staff to its accounting and/or grants management team. Views of responsible officials: Management will evaluate systems and processes to ensure time tracking procedures meet the standards outlined in the Uniform Guidance.
The U.S. Department of Agriculture (USDA) has adopted the Office of Management and Budget's Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards as codified in 2 CFR Part 200, through its own regulation at 2 CFR § 400.1. This adoption gives regulatory effect to 2 CFR § 200.430(f) which governs the allowability of fringe benefits under Federal awards. 2 CFR § 200.430(f) states that fringe benefits are allowable provided they are reasonable and required by law, employeremployee agreement or established policy. USDA's incorporation of this provision via 2 CFR § 400.1 makes it enforceable for all USDA-funded programs and awards including the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) program. OGAPP Manual 100.3, B2.4 Personnel Costs, states that even though costs of overtime/bonuses are chargeable to federal grants, they are only allowable to the extent that the costs comply with certain guidelines. For bonuses, they are limited to 3% of an employee's gross wages (not including fringes) or $1,500, whichever is less. The Ohio Department of Health (ODH) program administrator must approve all bonuses and enter a comment in GMIS in the project comments section. The District received approval from ODH via GMIS in 2023 for bonuses to be paid, however, due to a lack of internal controls, the bonuses were in excess of the amounts allowed under OGAPP (3%,or $1,500). The excess bonus amounts considered unallowable for the WIC program totaled $1,933. The unallowable bonus amounts paid are under the $25,000 federal threshold and therefore would not be considered as questioned costs for the program. The District should establish and implement internal controls to ensure all requirements from the federal and pass-through entities are followed to help ensure compliance and reduce the risk of misuse of funds.
2023-003 – Lack of Documented Approval for Payroll Transactions Program: ALN# 47.070 = Computer and Information Science and Engineering Federal Agency: National Science Foundation Federal Award Identification Number(s): 2216614, 2122756 Period: Year Ended December 31, 2023 Criteria: Under 2 CFR § 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During testing of payroll expenditures, the Organization was unable to provide documentation demonstrating supervisory approval for 7 of the 40 payroll transactions sampled. While payroll amounts appeared consistent with employee job description, pay rates, and timesheets, the required evidence of review and approval (e.g., approved timesheets, electronic timekeeping approval logs, or supervisor sign-offs) was not available for these items. Cause: The Organization’s existing payroll approval process is not consistently followed. Management reported that supervisory approval of employee hours is performed, but documentation is not always retained due to inconsistent use of the timekeeping system. Effect: Failure to maintain proper documentation of payroll approvals increased the risk that payroll costs charged to Federal programs may be unallowable or inaccurately allocated and unauthorized or incorrect payroll charges may go undetected. Questioned Costs: No questioned costs identified. Context: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend that the Organization: • Strengthen internal controls to ensure that all payroll transactions include documented supervisory approval prior to processing. • Ensure consistent use of the approved timekeeping system and require management to complete standardized approvals. • Implement periodic monitoring of payroll records to verify compliance with the approval process. Views of Responsible Officials: See management corrective action plan attached.
Condition: Employees who charged 100% of their time to the grant lacked required certifications or timecards documenting that their time was spent exclusively on grant-related activities. - In several instances, no timecards were available. - In other cases, available timecards showed no evidence of review or approval. - Timecards did not indicate program activity. - Timecards lacked evidence of supervisor approval. - Employees whose time was allocated to multiple programs had no indication of how their time was allocated on the time card. We did note, however, that most allocated employees were working on multiple contracts within the same Federal program, and that costs were allocated among the programs based on the number of beds in each facility, which appears to be a reasonable methodology. - Salaried employees did not have a method for indicating time worked. Cause: The organization failed to implement adequate internal controls to ensure compliance with federal timekeeping and documentation requirements for personnel expenses. Additionally, there appears to be a lack of understanding of the documentation and certification requirements under 2 CFR Part 200, Subpart E. Possible effect: The lack of proper documentation and certification creates a risk that unallowable costs were charged to the grant. Questioned cost: Undetermined. Recommendation: Develop and implement policies and procedures to ensure that timecards and/or certifications are completed and retained for all employees who charge 100% of their time to the grant. Implement a compliant system of time and effort reporting for employees whose time is allocated across multiple activities to align with 2 CFR §200.430(g)(vi). Conduct training for all employees and supervisors on the requirements for documenting and certifying time and effort for federal grants. Perform periodic reviews of timekeeping records and compensation charges to verify compliance with federal requirements.Views of responsible officials: During this period, Hope the Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We are also partnering with our new 3rd party payroll provider to set up time allocation for salaried employees.
FINDING 2023-005 – Allowable Costs: Significant Deficiency over Internal Controls over Compliance Assistance Listing Number Federal Agency/Pass-through Entity – Program Name Award Year Questioned Costs 64.033 VA Supportive Services for Veteran Families Program 2023 $0 Criteria: The time and effort reporting or compensation of personal services 2 CFR section 200.430 notes a non-federal entity must have written policies surrounding time and effort reporting that are consistently applied to both federal and non-federal activities. The actual percentage of employees’ time must be recorded and documented per funding source and not by budgets. Documentation must be maintained to support allocations for non-payroll and payroll disbursements charged to the grant. 2 CFR section 200.405 relates to allocable costs. A cost is allocable to a federal award if the goods and services involved are chargeable to that award in accordance with relative benefits received. Costs are allocable if they: • Are incurred specifically for the federal award • Benefit both the federal award and other work of the non-federal entity and can be distributed in reasonable proportion to the benefits received; or • Are necessary to the overall operation of the non-federal entity and are assignable in part to the federal award. Condition/Context: In a sample of 25 payroll disbursements, 11 salaried employees lacked adequate documentation to support the allocation of time and effort to federal programs. Additionally, 4 out of 25 non-payroll disbursements lacked a documented methodology or supporting evidence to justify the allocation of costs between programs. Effect: Expenses charged to the grant are not supported by records. Cause: There was turnover in the Organization which caused the inability to produce or find supporting documentation on how allocations are created inside the system. Repeat finding: This is not a repeat finding. Recommendation: The Organization should have written policies surrounding time and effort reporting and ensure the methodology is supported by source documents for all transactions. Views of responsible officials and planned corrective actions: Management agrees with the recommendation and has developed a corrective action plan to address the finding.
Finding 2023-002: 21.027 - Coronavirus State and Local Fiscal Recovery:COVID-19 Compliance Requirement: Allowable Costs/Cost Principles - Significant Deficiency Criteria: 2 CFR 200.430, subpart I - Compensation-personal service, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assuance that the charges are accurate, allowable, and properly allocated; • Reasonably reflect the total activity for which the employee is compensated; and • Be supported by documentation such as time sheets, time cards, or equivalent records that are approved by a supervisor with firsthand knowledge of the work performed. Condition: During testing of payroll transactions, it was noted that one employee out of eighteen tested charged to the federal award did not have a completed and approved timecard to support payroll costs for the period under review. As a result, the time and effort supporting payroll charges could not be verified. Effect: Without proper time and effort documentation, there is insufficient support to verify that payroll charges to the federal award accurately reflect the time worked on the project. This may result in unallowable costs being charged to the award. Questioned Cost: None Cause: The Organization did not consistently enforce its policy requiring employees to complete and submit time cards for all federally funded payroll costs. Recommendation: Management should ensure that all employees whose salaries are charged to federal awards complete and maintain appropriate time and effort documentation, such as signed time cards or certifications, in accordance with 2 CFR 200.430. Supervisors should review and approve these records regularly to verify the accuracy of payroll charges. Response: Implement procedures to ensure supervisors’ approval of all federally funded timecards by a set deadline. HR will run a “missing timecard report” each pay cycle to ensure time cards are properly completed. Will conduct annual training on federal compliance requirements.
Finding 2023-002: Lack of documentation of review and approval - Material Weakness Program name:Office for Coastal Management Assistance Listing: 11.473 Federal award Identification number: 20 NFWF 339630 Federal award year: 9/1/2020 - 9/30/2024 Federal awarding agency: U.S. Department of Commerce Criteria - In accordance with 2 CFR 200.303, recipients and subrecipients must establish, document and maintain effective internal control over Federal awards. These controls should be in compliance with Federal statutes, regulations, and the terms and conditions of the award, and should align with standards such as the “Standards for Internal Control in the Federal Government” (Green Book) or the COSO framework. This includes controls over: Payroll: Ensuring labor charges are accurate, allowable, and properly approved (2 CFR 200.430). Expenses: Ensuring proper documentation and approval. (2 CFR 200.400(d) ) Reporting: Ensuring financial reports are accurate, complete, and reviewed prior to submission (2 CFR 200.328). Condition - The Organization has limited written processes of certain transaction classes. There was a pervasive lack of documentation of approval over transactions, including payroll, expenses, and reporting. Cause - The Organization did not maintain or consistently apply documentation protocols for internal control reviews. Formal documentation practices were not in place during the audit period. Effect - Lack of documentation as evidence that controls over compliance were being performed. Documentation should be maintained as evidence that sufficient control activities are in place and would effectively prevent or detect and correct noncompliance. Controls must be followed for every transaction and documentation of the control being performed must be maintained. Questioned costs - None identified. Perspective - The deficiency was pervasive across multiple compliance areas and was not isolated to a specific transaction or department. The scope indicates a systemic control weakness during the audit period. Identification of Repeat Findings - This is a repeat finding from the prior year (Finding 2022-002). As a result of the 2022 audit report, issued in October 2025, the Organization began the process of developing updated policies for compliance. In 2025, the Organization formally adopted new policies and procedures that align with the internal control standards per 2 CFR Part 200. Recommendation - We recommend that the Organization ensure updated policies and procedures are implemented and consistently applied. This includes: Documented review and approval of all transactions related to payroll, expenses, and reporting. Maintenance of written evidence supporting such reviews. Regular training and internal monitoring to ensure control procedures are consistently followed. Management response - Management agrees with this assessment and has committed to a corrective action plan. Management has also engaged with a new accounting firm to oversee the financial reporting functions at the Organization.
2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 CFR § 200.302(b)(6) states the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Additionally, for Federal awards, the Uniform Guidance requires a written policy for the procurement requirements outlined in 2 CFR § 200.318(c)(1), 2 CFR § 200.318(c)(2), and 2 CFR § 200.320(B) 2 CFR 200.302(b)(7) requires written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of this part and the terms and conditions of the Federal award. 2 CFR 200.430 states that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, 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 a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR 200.431 requires established written leave policies if the entity intends to pay fringe benefits. 2 CFR 200.464(a)(2) requires reimbursement of relocation costs to employees be in accordance with an established written policy must be consistently followed by the employer. 2 CFR 200.475 requires reimbursement and/or charges to be consistent with those normally allowed in like circumstances in the non-Federal entity's non-federally-funded activities and in accordance with non-Federal entity's written travel reimbursement policies. The General Health District did not have written policies as required by Uniform Guidance. The failure to implement written policies as required by Uniform Guidance could result in noncompliance with the District’s federal programs. The General Health District should adopt written policies in accordance with the Uniform Guidance.
Employee not paid approved salary rate and payroll allocation based on incorrect pay rate. Timesheets missing approval. 93.011 National Organizations for State and Local Officials 93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security 93.341 Analyses, Research and Studies to Address the Impact of CMS Programs on American Indian/Alaska Native (AI/AN) Beneficiaries and the Health Care System Serving these Beneficiaries 93.421 Strengthening Public Health Systems and Services Criteria: 2 CFR 200.430 states “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." Condition: During our testing of payroll, we noted twenty one instances of incorrect pay rates, missing timesheet approvals and twenty four payroll allocations based on incorrect pay rates. We consider these to be a significant deficiency in internal control over compliance relating to activities allowed and unallowed and allowable costs/cost principles requirements and is not considered a repeated finding. Statistical sampling was not used in making sample selections. Questioned costs: $4,245 Effect: Employee compensation was not processed using the authorized salary rate, resulting in payroll allocations based on an incorrect pay rate. Additionally, timesheets lacked the required approval signatures. Overall this could result in an employee being incorrectly paid for time worked. Cause: This is due to lack of controls over document retention resulting from employee turnover. Recommendation: Auditors recommend the Organization maintain proper salary rate approval and ensure all pay rates are approved by an appropriate individual and properly paid to employees. We also recommend timesheets should be approved by an appropriate individual and payroll allocations should be based on proper salary rates. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS04200-18-01 and H80CS04200-19-00 Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Compliance and Significant deficiency in internal control over compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (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 and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: Time and effort documentation was not available for one transaction. Questioned Costs: Unknown. Context: One (1) of forty (40) allowable cost transactions selected for testing. Cause: The employees' supervisor did not submit the necessary time and effort form and that individual is no longer employed by the Organization. Effect: Amount charged to the grant may be inconsistent with actual time spent on grant activities. Repeat Finding: No. Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” The records must also “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: A sample of 7 payroll transactions were selected for testing from a population of 67 transactions. The sample included all personnel with time allocated to the program. Through testing, it was found that there were no records maintained to support the portion of time and effort dedicated to the program. Cause and Effect: Due to staff turnover during the year, the Organization neglected to maintain the required documentation. The Organization receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the Organization may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate. Questioned Costs: Salary and related benefits of employees charged to the program = $223,234 Identification as a repeat finding: There was no single audit requirement in the prior year and therefore, this finding is not reported as a repeated finding. Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023.002: Activities Allowed or Unallowed Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 Grants for New and Expanded Services under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (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) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition There was no evidence that management reviewed and approved the payroll cost charged to the major program to ensure it was an allowable cost under the Uniform Guidance, as evidenced by a reviewer's signature on the labor report. Cause The Center's internal controls over payroll were not consistently followed. Effect Unallowable expenses could be charged to the grant. Questioned Costs None. Context Out of the 25 payroll transactions selected for testing, none of them illustrated documentation of formal approval. Identification as Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that all labor reports are reviewed and show formal approval before payroll is submitted. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will implement additional controls to ensure payroll expenditures are being formally reviewed and approved.
Finding 2023‐001: Significant Deficiency, Internal Control Over Compliance Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 – COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Award Year: 2021 Federal Award Identification: PRF 20210001 Pass‐Through Entity: N/A Criteria: Per 2 CFR 200.303 and 2 CFR 200.430(i), a non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award and establishes the standard for documentation of personnel expenses. Condition: Payroll expenses are an allowed expense according to the guidance and FAQs generated by HRSA. The Medical Center should have controls in place whereby all expenses are reviewed prior to submission to ensure the expense is for the proper purpose. Cause: There was no policy implemented to require the documented approval of a corrected time card. Effect: For one of twenty‐five payroll expenses selected, there was no approval of a corrected time card prior to the payroll being submitted. Questioned Costs: $‐0‐ Perspective: The payroll expense was an allowable costs under the guidance issue by HHS. This finding does not generate any questioned costs or unallowable costs being used in the PRF submission. Recommendation: We recommend the Medical Center implement a process whereby all timesheets (original and corrected) have to be approved by a supervisor prior to payroll being generated and that approval is documented and maintained. Views of Responsible Officials and Planned Corrective Action: Management concurs with auditors’ finding and recommendation. Management’s Response: See attached corrective action plan.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.
Finding 2023-002 Timesheet Allocations (Ukraine) Information on the Federal Program: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Our audit of Global Communities Ukraine revealed instances in which salary allocations charged to federal grants did not accurately reflect actual project allocations reported on employee timesheets. Subsequent to audit fieldwork, Global Communities management performed a detailed review of all timesheets and recorded a reallocation to correctly state salary allocations charged to grants. Cause: Ukraine salary allocations recorded in the general ledger were inadvertently miscalculated in comparison to time reported on employee timesheets. Effect or Potential Effect: Salary expense could be over or under charged to Ukrainian federal projects. Questioned Costs: N/A – management performed a detailed analysis and reallocation that is reflected in the accompanying Schedule of Expenditures of Federal Awards. Context: We selected a sample of employee salaries charged to Ukrainian federal projects. The sample was a statistically valid sample. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the headquarters office provide additional training to the Ukraine field office to strengthen internal controls around the salary allocation process. This is to ensure that salary allocation accurately reflects employee time reported on monthly timesheets.