Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for documenting personnel expenses. The current standards require that the distribution of an employee's salary or wages among specific activities or cost objectives must be supported by adequate documentation if the employee works on more than one federal award or a federal award and a non-federal award. While testing payroll expenditures coded to the Education Stabilization Fund, four instances were noted in which an employee's salary was allocated to the Education Stabilization Fund and to other programs, but no time and effort reports or other documentation were provided to document the time the employee spent working on a specific program. Controls were not in place to ensure that the Board maintained time and effort reports or other adequate documentation that supported the distribution of employees' salaries to the Education Stabilization Fund. As a result, the Board is not in compliance with Uniform Guidance as it pertains to the documentation required for personnel expenses charged to the Education Stabilization Fund.
Criteria: 2 CFR 200.430(i) requires the auditee to establish and maintain effective internal control over the allocation of personnel expenses whereby charges to Federal awards for personnel-related expenditures are supported by official records of 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. Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable and properly allocated. Condition: Personnel expenses were not reconciled to T&E reports during the fiscal year, which resulted in personnel expenses being under-claimed. Cause: Internal controls surrounding time and effort reporting were designed to perform allocation reconciliations based on the award period instead of the fiscal year. Questioned costs: none. Recommendation: We recommend that management implement a process whereby reporting is reconciled based on fiscal year. We recommend that all personnel expenditures allocated to grants are tracked, reviewed, and approved prior to recording in the general ledger. Views of responsible officials and planned corrective actions: See attached corrective action plan.
Criteria: 2 CFR 200.430(i) requires the auditee to establish and maintain effective internal control over the allocation of personnel expenses whereby charges to Federal awards for personnel-related expenditures are supported by official records of 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. Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable and properly allocated. Condition: Personnel expenses were not reconciled to T&E reports during the fiscal year, which resulted in personnel expenses being under-claimed. Cause: Internal controls surrounding time and effort reporting were designed to perform allocation reconciliations based on the award period instead of the fiscal year. Questioned costs: none. Recommendation: We recommend that management implement a process whereby reporting is reconciled based on fiscal year. We recommend that all personnel expenditures allocated to grants are tracked, reviewed, and approved prior to recording in the general ledger. Views of responsible officials and planned corrective actions: See attached corrective action plan.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Child Nutrition Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation of leave and errors in payments of approved salaries. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Child Nutrition Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation of leave and errors in payments of approved salaries. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Child Nutrition Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation of leave and errors in payments of approved salaries. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Child Nutrition Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation of leave and errors in payments of approved salaries. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Child Nutrition Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation of leave and errors in payments of approved salaries. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Special Education Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation and proration of salaries paid to employees. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Special Education Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation and proration of salaries paid to employees. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Special Education Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation and proration of salaries paid to employees. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation, and states that the compensation should follow an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the "Board") Policies and Procedures Manual states, "Except as established and governed by the terms of a special employment contract, Board employees will be compensated at rates of pay that are approved by the Board" and "When required, such salary or compensation rates will be included in a schedule to be developed and adopted by the Board in accordance with state law". When reviewing the Special Education Cluster, sixty expenditures were randomly selected for testing. Five of the sixty expenditures tested included errors related to the calculation and proration of salaries paid to employees. Controls were not in place to ensure personnel were properly compensated in accordance with approved rates of pay and approved salary schedules. As a result, the Monroe County Board of Education (the “Board”) did not calculate salaries paid to employees in accordance with the Board’s policies.
Finding Number: 2023-001 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Per District Personnel Issuance No. 2021-10 (Approval Required) - "Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Employees may submit overtime requests in PeopleSoft. To submit a request, go to the main employee self-service page and access the navigator. Click “Self Service,” next “Time Reporting,” then “Report Time,” and finally “Overtime Requests.” Once an employee submits an overtime request, the employee’s supervisor and, if required by PeopleSoft any additional designated agency personnel, must review and approve the request in PeopleSoft for the employee to be authorized to receive overtime pay.” Per District Personnel Issuance No. 2018-00 (Annual Leave) effective April 21, 2018 “Using Annual Leave” - An employee may use accrued annual leave at any time during the leave year if they receive approval from their immediate supervisor or the agency head responsible for the employee’s timesheet. If an employee wishes to use their accrued annual leave, they must: 1. Submit a request in advance to use annual leave to their manager or supervisor. 2. Receive approval from the manager or supervisor; and 3. Record the approved leave taken on their timesheet in PeopleSoft. Condition – We noted that for six (6) out of a sample of seven (7) employees tested of total costs sampled of $30,993, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet. Questioned Costs – Known amount is $28,093. Context – This is a condition identified per review of DHS/ESA’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the SNAP program in fiscal year 2023 were $16,063,809. Effect – Without adequate internal controls in place to ensure costs are properly reviewed for allowability, DHS/ESA could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Cause – DHS/ESA did not follow its own internal controls and policies and procedures to ensure that documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet is obtained and maintained. Recommendation – We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of scheduled leave or overtime is obtained and maintained. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DHS concurs with the finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-001 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Per District Personnel Issuance No. 2021-10 (Approval Required) - "Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Employees may submit overtime requests in PeopleSoft. To submit a request, go to the main employee self-service page and access the navigator. Click “Self Service,” next “Time Reporting,” then “Report Time,” and finally “Overtime Requests.” Once an employee submits an overtime request, the employee’s supervisor and, if required by PeopleSoft any additional designated agency personnel, must review and approve the request in PeopleSoft for the employee to be authorized to receive overtime pay.” Per District Personnel Issuance No. 2018-00 (Annual Leave) effective April 21, 2018 “Using Annual Leave” - An employee may use accrued annual leave at any time during the leave year if they receive approval from their immediate supervisor or the agency head responsible for the employee’s timesheet. If an employee wishes to use their accrued annual leave, they must: 1. Submit a request in advance to use annual leave to their manager or supervisor. 2. Receive approval from the manager or supervisor; and 3. Record the approved leave taken on their timesheet in PeopleSoft. Condition – We noted that for six (6) out of a sample of seven (7) employees tested of total costs sampled of $30,993, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet. Questioned Costs – Known amount is $28,093. Context – This is a condition identified per review of DHS/ESA’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the SNAP program in fiscal year 2023 were $16,063,809. Effect – Without adequate internal controls in place to ensure costs are properly reviewed for allowability, DHS/ESA could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Cause – DHS/ESA did not follow its own internal controls and policies and procedures to ensure that documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet is obtained and maintained. Recommendation – We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of scheduled leave or overtime is obtained and maintained. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DHS concurs with the finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-001 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Per District Personnel Issuance No. 2021-10 (Approval Required) - "Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Employees may submit overtime requests in PeopleSoft. To submit a request, go to the main employee self-service page and access the navigator. Click “Self Service,” next “Time Reporting,” then “Report Time,” and finally “Overtime Requests.” Once an employee submits an overtime request, the employee’s supervisor and, if required by PeopleSoft any additional designated agency personnel, must review and approve the request in PeopleSoft for the employee to be authorized to receive overtime pay.” Per District Personnel Issuance No. 2018-00 (Annual Leave) effective April 21, 2018 “Using Annual Leave” - An employee may use accrued annual leave at any time during the leave year if they receive approval from their immediate supervisor or the agency head responsible for the employee’s timesheet. If an employee wishes to use their accrued annual leave, they must: 1. Submit a request in advance to use annual leave to their manager or supervisor. 2. Receive approval from the manager or supervisor; and 3. Record the approved leave taken on their timesheet in PeopleSoft. Condition – We noted that for six (6) out of a sample of seven (7) employees tested of total costs sampled of $30,993, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet. Questioned Costs – Known amount is $28,093. Context – This is a condition identified per review of DHS/ESA’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the SNAP program in fiscal year 2023 were $16,063,809. Effect – Without adequate internal controls in place to ensure costs are properly reviewed for allowability, DHS/ESA could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Cause – DHS/ESA did not follow its own internal controls and policies and procedures to ensure that documentation to show the preapproval of the scheduled leave and overtime approved on the timesheet is obtained and maintained. Recommendation – We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of scheduled leave or overtime is obtained and maintained. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DHS concurs with the finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-005 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Agriculture Special Supplemental Nutrition Program for Women, Infants and Children (WIC) ALN: 10.557 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – From a sample of 40 payroll transactions, we noted five (5) transactions for one employee that did not work on the program, thus, there should be no hours charged to the program during the year. Per review of the total payroll charged to the program for the year for this employee, we noted $32,290 that should not have been charged to the program. Questioned Costs – Known amount is $32,290. Context – This is a condition identified per review of DC Health’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the WIC program in fiscal year 2023 were $1,073,965. Effect – DC Health was unable to demonstrate that the payroll expenditures charged to the WIC program were allowable expenses in accordance with 2 CFR Part 200.430. Cause – DC Health did not adhere to its internal control policies and procedures for reviewing the eligibility and allowability of payroll expenditures charged to the WIC program. Recommendation – We recommend that DC Health strengthen its policies and procedures to ensure that only allowable expenses are charged to the program as required by 2 CFR 200.430. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DC Health concurs with the finding. DC Health complies with local and federal requirements for regular and routine review of budgeted employee time and alignment with allowable costs and hours worked. Staff duties are documented in performance plans, SMART goals, logs/calendars and reports revised by supervisors. The exception found in the sample was corrected in January 2024 when the employee was found to be budgeted partly on the WIC grant. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-005 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Agriculture Special Supplemental Nutrition Program for Women, Infants and Children (WIC) ALN: 10.557 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – From a sample of 40 payroll transactions, we noted five (5) transactions for one employee that did not work on the program, thus, there should be no hours charged to the program during the year. Per review of the total payroll charged to the program for the year for this employee, we noted $32,290 that should not have been charged to the program. Questioned Costs – Known amount is $32,290. Context – This is a condition identified per review of DC Health’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the WIC program in fiscal year 2023 were $1,073,965. Effect – DC Health was unable to demonstrate that the payroll expenditures charged to the WIC program were allowable expenses in accordance with 2 CFR Part 200.430. Cause – DC Health did not adhere to its internal control policies and procedures for reviewing the eligibility and allowability of payroll expenditures charged to the WIC program. Recommendation – We recommend that DC Health strengthen its policies and procedures to ensure that only allowable expenses are charged to the program as required by 2 CFR 200.430. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DC Health concurs with the finding. DC Health complies with local and federal requirements for regular and routine review of budgeted employee time and alignment with allowable costs and hours worked. Staff duties are documented in performance plans, SMART goals, logs/calendars and reports revised by supervisors. The exception found in the sample was corrected in January 2024 when the employee was found to be budgeted partly on the WIC grant. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-014 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 – 09/20/2023 Department of Behavioral Health (DBH); Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During our tests of the design and implementation of internal controls, we noted the following issues: DBH did not effectively implement controls over employee premium pay benefits. • For two (2) out of 60 samples, we identified exceptions to the hours charged to the program. In one instance, there were 24 hours charged to the program on a single day for one employee. In addition, we also noted an instance of charging of hours within the “not worked” code and incorrect hours were charged to the project. At DOEE, employees charge hours worked each pay period on a time sheet to specific cost centers or combo codes as referred by the agency. • For one (1) out of 60 samples, we noted that the holiday hours have not been allocated between programs proportionally as required by the District’s policies, as such, incorrect hours were charged to the projects. Questioned Costs – Not determinable. Context – This is a condition identified per review of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Coronavirus State and Local Fiscal Recovery Funds program in fiscal year 2023 were $40,106,238. Effect – Without internal controls operating as designed, the CSLFRF program was unable to demonstrate that the payroll expenditures charged to the program accurately reflected the costs incurred for the program. Cause – The CSLFRF program did not follow its own internal control policies, procedures and controls to ensure that payroll costs recorded are properly reviewed and approved. Recommendation – We recommend that the CSLFRF program fully implement its plan to deploy policies and procedures to ensure that payroll costs are recorded accurately. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DBH and DOEE concur with the findings. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Finding Number: 2023-019 Prior Year Finding Number: 2022-010 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: Government Department/Agency: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2022 – 09/30/2023 Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish 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 Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Per District Personnel Issuance No. 2021-10 (Approval Required) - "Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Employees may submit overtime requests in PeopleSoft. To submit a request, go to the main employee self-service page and access the navigator. Click “Self Service,” next “Time Reporting,” then “Report Time,” and finally “Overtime Requests.” Once an employee submits an overtime request, the employee’s supervisor and, if required by PeopleSoft any additional designated agency personnel, must review and approve the request in PeopleSoft for the employee to be authorized to receive overtime pay.” Per District Personnel Issuance No. 2018-00 (Annual Leave) effective April 21, 2018 “Using Annual Leave” - An employee may use accrued annual leave at any time during the leave year if they receive approval from their immediate supervisor or the agency head responsible for the employee’s timesheet. If an employee wishes to use their accrued annual leave, they must: 1. Submit a request in advance to use annual leave to their manager or supervisor. 2. Receive approval from the manager or supervisor; and 3. Record the approved leave taken on their timesheet in PeopleSoft. Condition – During our testwork for Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll), we noted: • For seventeen (17) out of a sample of 40 employees tested, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation that the annual leave or overtime hours worked by the employee during the selected payperiods were preapproved. • For one (1) out of a sample of 40 employees tested, DHS/ESA was unable to provide an explanation of the identified variance between the salary earned and the amount included on the paystub. • For one (1) out of a sample of 40 employees tested, DHS/ESA was unable to provide an explanation and support for the benefit refund taxable included on the paystub and the variance between the hours on the timesheet and on the pay stub. Questioned Costs – Not determinable. Context – This is a condition identified per review of DHS/ESA’s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the TANF program in fiscal year 2023 were $15,577,889. Effect – DHS/ESA was unable to demonstrate that annual leave or overtime hours charged to the federal program was approved in advance in accordance with the internal policies and procedures of the agency. In addition, without adequate internal controls in place to ensure that documentation that supports the costs are properly maintained, costs could be charged that are not properly approved. Cause – DHS/ESA did not follow its own internal controls and policies and procedures to ensure that authorization forms evidencing the preapproval of annual leave or overtime hours are obtained and maintained as well as support of salary and benefits earned. Recommendation – We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of annual leave or overtime hours is obtained and maintained. In addition, we recommend that the agency strengthen their policies and procedures to ensure that transactions are properly supported. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DHS concurs with the finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
Federal Agency: U.S. Department of Health and Human Services Compliance Requirement: Activities Allowed, Allowable Costs (Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance Federal Program: 93.696 – Certified Community Behavioral Health Clinics Grant Award: 1H79SM086741-01 Condition/Context During testing over payroll, we noted that out of ten (10) employees selected for testing, documentation of time and effort for one employee was not sufficiently documented, as the allocation of time and effort spent on program-related and general and administrative activities according to the time reporting system did not agree with the related accounting records. Criteria 2 CFR part 200.430 of the Uniform Guidance requires that “charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must….be incorporated into the official records and…support the distribution of the employee’s salary or wages among specific activities.” Cause Sufficient documentation related to time and effort was not maintained by management for the above employee. Effect It could not be determined if the excess time and effort was related to the federal award programs and, therefore, appropriately included as federal expenditures. Questioned Costs Not determinable since it was not clear if the employee partially or fully worked on program-related activities. Recommendation We recommend that management implement procedures to ensure that all time and effort spent on federal award programs be adequately documented with underlying contracts, offer letters, personnel action forms, and time sheets. Views of Responsible Officials and Planned Corrective Actions See corrective actions plans section.
Item 2023‐002 Written policies, procedures, and standards of conduct COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027 U.S. Department of Treasury Grant period: Year ended September 30, 2023 Questioned Costs – $0 Condition – The City does not have all of the written policies, procedures and standards of conduct required by UG. Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐ Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management § 200.305 Payment § 200.319 Competition § 200.320 Methods of procurement to be followed § 200.430 Compensation—personal services § 200.431 Compensation—fringe benefits Cause of Condition – The City has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the City implement the required written policies and procedures. Management’s Response – Management agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.
Finding No. 2023-003: Internal Control over Payroll – Significant Deficiency in Internal Control over Compliance U.S. Agency for International Development, USAID Foreign Assistant for Programs Overseas, Assistance Listing Number 98.001. Criteria Section 200.405 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) indicates that a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. This standard is met, among other things, if the cost charged is incurred specifically for the federal award. Also, under cost principles established by 2 CFR Section 200.430, 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 and be incorporated into the official records of the non-Federal entity. Context During our testing of payroll expenditures, we noted an instance for one employee where the time worked on the award did not have support to document that the payroll expenditure was properly approved and an instance where a bonus was awarded to an employee, where the allocation for time worked on the federal award for the specific pay period was used as the allocable base for the overall bonus instead of the period to which the bonus was related. The total amount recorded to the grant related to this was $2,563. Cause There was a breakdown in internal control where one employee’s timesheet was not reviewed by their supervisor. Also, when reviewing the allocable charges to the federal award, there was a breakdown in internal control when preparing the allocation for the pro-rated salary charges incurred related to the federal award. Effect The amount charged to the federal award was not properly authorized. If the compensation costs allocated to the grant cannot be supported in accordance with the Uniform Guidance, the granting agency could determine that these costs are not allowable. Questioned Costs The amount did not exceed $25,000 and therefore is not required to be reported. Recommendation The Organization’s program staff and management should ensure that the amounts charged to the federal award are properly approved and accurate. Monthly reconciliation of all expenses, including of salaries charged to program versus actual hours incurred should be performed timely. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan
Finding 2023-002 Significant deficiency in internal controls over compliance and instances of noncompliance related to allowable costs/cost principle compliance requirements. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart E section 2 CFR 200.430 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires direct costs to be allocated based on the proportional benefit received by each award. Condition/Context For the year ended September 30, 2023, in a sample of 25 transactions, there were three instances of payroll costs being charged to the award that were not supported by proper documentation of the allocation applied. Effect/Potential Effect DRW was unable to substantiate allocations of payroll costs based on documentation retained. Questioned Costs $125.03 Cause DRW’s internal controls related to payroll costs allocation was not sufficient to prevent or detect errors in compliance with the standards and to ensure consistent treatment with policies and procedures. Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure that all payroll costs charged to the federal awards are supported by proper documentation. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Finding 2023-002 Significant deficiency in internal controls over compliance and instances of noncompliance related to allowable costs/cost principle compliance requirements. Federal Agency: U.S. Department of Health and Human Services Program Title: Developmental Disabilities Basic Support and Advocacy Grants Assistance Listing Number: 93.630 Awards Number: 2201WAPADD-00 & 03; 2001WAPAPH-00 & 01 Award Period: 10/01/2021 - 9/30/2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart E section 2 CFR 200.430 (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires direct costs to be allocated based on the proportional benefit received by each award. Condition/Context For the year ended September 30, 2023, in a sample of 25 transactions, there were three instances of payroll costs being charged to the award that were not supported by proper documentation of the allocation applied. Effect/Potential Effect DRW was unable to substantiate allocations of payroll costs based on documentation retained. Questioned Costs $125.03 Cause DRW’s internal controls related to payroll costs allocation was not sufficient to prevent or detect errors in compliance with the standards and to ensure consistent treatment with policies and procedures. Repeat Finding Not applicable Recommendation We recommend that DRW implement internal controls to ensure that all payroll costs charged to the federal awards are supported by proper documentation. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Finding 2023-001 – Allowable Activities and Costs of Provider Relief Fund Significant Deficiency in Internal Control over Compliance Program: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Grantor: U.S. Department of Health and Human Services Pass-Through Entity: None Criteria: Per 2 CFR 200.430(i), personnel costs charged to federal grants are required to be supported by documentation including time records. Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over Federal awards 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. Condition: Our audit procedures over the calculation of COVID patient days used to allocate the payroll cost to the PRF/ARP federal program disclosed the amounts were not properly calculated. Cause: The Medical Center has controls in place to review the calculation; however, the control did not operate to identify an error in the calculation of COVID patient days. Effect: The error in the calculation resulted in underreporting payroll costs allowed to be charged to PRF/ARP in the amount of $566,272. Questioned Costs: None Perspective: The error in the calculation resulted in underreporting payroll costs allowed to be charged to PRF/ARP in the amount of $566,272. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Medical Center implement additional internal controls over compliance in order to properly identify any errors in calculation. View of Responsible Officials: See management’s response to the finding in the accompanying Corrective Action Plan.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-003 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR 200.430 i(i)(vii) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and there should be support to the distributions of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: In gaining our understanding of controls over allowable costs for payroll, we noted that the Organization did not have proper documentation of time and effort analysis to support charges to the grants. Cause: The Organization used the grant budget to charge salaries to the grant but did not have any documentation showing an analysis of actual time worked on those grants. Effect: The hours charged to a program could be under stated or overstated if the actual hours differed from the grant budget hours. Auditor’s Recommendation: We recommend implementing the use of time sheets with grants or personnel activity reports that document actual hours worked by personnel on each grant. Management Response: Management will implement time sheets for all employees that work on grants that specify what grants they are working on, number of hours for each for all payrolls in 2024 to correct this problem going forward. In addition, the timesheets will include what functions those
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
Prior Year Finding Number: 2022-002 Compliance Requirement: Allowable Costs/Cost Principles Program: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Pass through Entity: District of Columbia Office of the Deputy Mayor for Education -Office of Out of School Times Grant and Youth Outcomes, District of Columbia Human Services Rehousing Stabilization Program - Safe Passage Safe Blocks, D.C. Office of the Deputy Mayor Office Victim Services and Justice Grants and Office of Victim Services and Justice Grants Successful Reentry Program CFDA #: 21.027 Award #: 2023-SPSB-011-CSC, 2023-CSC-04, CW1010626, and 2023-AARPA-2004 Award Year: 10/01/2022-09/30/2023! Criteria: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.430 – Factors Affecting Allowability of Costs - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3). The Personnel Section of the Executed Contract indicated specifies that: A. All staff, volunteers, and contractors, collectively called program personnel, who have regular unsupervised contact and direct interactions with youth, must possess the requisite training, qualifications, clearances, and competency to perform the duties to which they are assigned. B. All program personnel must have the following background checks in order to comply with the District of Columbia’s Criminal Background Checks for the Protection of Children Act of 2004. DC Code §§ 4-1501.01 – 4-1501.11 and other OST Office requirements: • DC Child and Family Services Agency (CFSA) Child Protection Registry (CPR); • Federal Bureau of Investigation (FBI) Criminal Background Check; • Metropolitan Police Department (MPD) Criminal Background Check; and • National Sex Offender Registry. C. Any program personnel with the following felony convictions are not permitted to work or volunteer with children and youth: 1. Murder, attempted murder, manslaughter or arson; 2. Assault, battery, assault and battery, assault with a dangerous weapon, mayhem, or threats to do bodily harm; 3. Burglary; 4. Robbery; 5. Kidnapping; 6. Illegal use or possession of a firearm; 7. Sexual offenses, including indecent exposure; promoting, procuring, compelling, soliciting, or engaging in prostitution; corrupting minors (sexual relations with children); molesting; voyeurism; committing sex acts in public; incest; rape; sexual assault; sexual battery; or sexual abuse; but excluding sodomy between consenting adults; 8. Child abuse or cruelty to children; or 9. Unlawful distribution or possession of or possession with intent to distribute, a controlled substance. Condition: We sampled 60 payroll expense transactions and noted the following: • Four (4) instances in which time charged to this program was not recorded in the timesheets reviewed for the periods tested. The total of these transactions were $12,087. • Six (6) payroll transactions did not satisfy the prohibited felony background requirements as specified in the Safe Passage Safe Block grant agreement for personnel hired under this award. The total of these transactions were $16,404. • Six (6) payroll transactions from the Safe Passage Safe Block award did not show evidence of clearance by the D.C. Child and Family Services Child Protection Registry (CPR) and 2 CPRs provided were outside of the period tested. In addition, 5 CPR and First Aid training documentation were not provided. The total of these transactions were $15,585. Two (2) files did not show evidence of Metropolitan Police Department (MPD) criminal background checks as a condition for employment. Eight (8) MPD files requested were not provided. The total of these transactions were $39,102. Twenty-two (22) National Sex Offenders Registry records were not provided for persons hired under the program. This registry was managed directly by a District Agency and was not submitted to CSC. The total of these transactions were $71,408. Questioned Costs: $154,586 Context: This is a condition identified per review of CSC’s compliance with the specified requirements using a statistically valid sample. The known amount of the payroll transactions totaled $154,586. Effect: CSC is not in compliance with the stated provisions of the grant awards. Failure to properly review and support expenses can result in noncompliance with laws and regulations along with loss of funding. Cause: CSC did not appear to have adequate policies and procedures in place to ensure compliance with the required stipulations regarding background. Recommendation: We recommend that CSC ensure that personnel hired under the grant meet all the background and other checks within the stipulated time frame outlined in the grant agreement. We also recommend that CSC improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for expenses incurred and reported.
2023-001: Allocable Costs/Cost Principles - Reporting of Payroll based on budget. Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086680-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal controls and material noncompliance with laws and regulations Repeat Finding: No Criteria: Per 2 CFR 200.430(i)(1)(viii)(c), the auditee’s system of internal must include control processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The Authority allocated wages and fringe benefits to the program based on the grant budget, with no adjustment made to actual time spent. Identification of How Likely Questioned Costs Were Computed: A schedule was prepared of time and attendance reports for the year which was compared to the amount charged to the grant. Known Questioned Costs: $19,693 Context: The Authority charged wage and fringe benefit for all employees providing services under the Certified Community Behavioral Health Clinic Expansion Grant based on budget amounts for the fiscal year. A schedule was prepared by management of the time spent on the grant for all employees for the year, which was compared to budget. Cause/Effect: Management was under the understanding that since the budget had been approved by the grantor that they were allowed to charge the budgeted amount to the grant. As a result, wages and fringe benefits charged to the grant were overstated based on time and attendance reports. Recommendation: We recommend the Authority review all federally funded grants and implement a review process to ensure the amount charged to the Federal award is based on the time the employees spend on providing the services. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
Finding Number: 2023-001 Federal Agency: U.S. Department of Housing and Urban Development ALN: 14.157 Compliance Requirement: Special Test and Provisions – Use of Project Funds-Payroll Activities Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records: • Reasonable reflects the total activity for which the employee is compensated across all grant-related and non-grant-related activities (100% effort) and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – For ALN 14.157, we sampled and selected 25 out of 173 payroll expenditures and noted six (6) instances where timesheets were not available for review. Questioned Cost – $9,172 Context – This is a condition identified per review of The Project’s compliance with the specified requirements using a statistically valid sample. The total payroll expenditure charged to the program in fiscal year 2023 is $203,516. The total amount sampled is $24,219. The known amount of the exceptions is $9,172. Effect – The Project is not in compliance with he stated provision. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Timesheets appear to have been misfiled and were not available for review upon request. Recommendation – Management should ensure timesheets are properly filed and be available for review upon request. Views of Responsible Officials – Timesheets were misfiled by a new employee responsible for sorting and filing timesheets. Several employee folders were searched for misplaced timesheets, and some were found; However, the six missing timesheets were not found. This program is physically located in St. Thomas, and the original timesheets arrive at the administrative office about a week after the payroll is processed. A faxed copy of the original timesheets is used for review before processing payroll. Going forward, time sheet sorting and filing by new employees will be monitored more closely for proper sorting and filing
Finding 2023-010 – Salaries and Wages (Allowable Costs) Information on Federal Programs: Environmental Finance Center Grants – Assistance Listing No. 66.203 U.S. Environmental Protection Agency Grant No. 539001D, Grant period July 1, 2022 - September 30, 2023 Grant No. 5127620, Grant period October 1, 2022 - September 30, 2023 Grant No. 5126607, Grant period July 1, 2022 - September 30, 2023 Criteria or Specific Requirements: According to 2 CFR Section 200.430(g), charges to Federal grants for salaries and wages must be based on records that accurately reflect the work performed and the records must: a. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b. Be incorporated into the official records of the non-Federal entity; c. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100 percent of compensated activities; d. Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; e. Comply with the established accounting policies and practices of the non-Federal entity; f. Support the distribution of the employee's salary or wages among specific activities or cost objectives 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; and g. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards. Condition: For the period from October 2022 through May 2023, U.S. Water Alliance did not have a timekeeping system in place. A timekeeping system was implemented in June of 2023, that provides for employees to record hours worked for specific cost objectives, including Federal grants. There are limitations to the timekeeping system’s capabilities. One is no availability to run timesheet reports for closed grants after the grant period ends. Second is the need to manually adjust hours transferred from the timekeeping system to the payroll processing system due to semi-monthly payroll processing and the need to have total number of hours equal to 86.67 for salaried employees. For these three awards, budget estimates or relative level of effort by percent of full-time employees and active projects were used throughout the entire grant period, even after the timekeeping system was put in place. No reconciliation between the budget estimates or relative level of effort by percent of full-time employees and active projects and the hours recorded in the timekeeping system was completed even for the period in which the timekeeping system was in place. Cause: A timekeeping system was not implemented until June 2023. Effect: Salary expenditures that are not charged in accordance with the standards referenced above may be questioned or disallowed by the Federal agency. Perspective: Qualitative reports on activities on these three awards indicate there was work performed; however, due to lack of quantitative support for hours charged to the grant, it is unable to be determined whether the number of hours and ultimately dollars charged for personnel costs for these three awards are the actual hours spent on activities for these three awards. Questioned Costs: Undetermined. Repeat Finding: Not applicable. Recommendation: U.S. Water Alliance should utilize the timekeeping system data for reporting personnel costs for all Federal awards. U.S. Water Alliance should also revisit its procedures for transferring data from the timekeeping system to the payroll processing system and ultimately the general ledger, and should implement proper internal controls to ensure that the amount of hours and salary expenditures charged to grants in the general ledger reconcile to the hours reported by the timekeeping system and amounts reported by the payroll processing system. Views of Responsible Officials and Planned Corrective Actions: A new timekeeping system was implemented in June 2023 to allocate work hours specific to cost objectives, including Federal Grants. While there are limitations to the system, the allocations are transferred from the timekeeping system upon supervisor approval to the Prism (HRIS) Portal and used to prepare payment vouchers. From the HRIS system, we can produce labor allocation reports reflecting how the time was originally allocated in the timekeeping system. The US Water Alliance indeed operates on a semi-monthly payroll period. It has allowed the Alliance to have fixed pay dates though they may not fall on the same day of the week each month. If the pay date falls on a weekend or holiday, the pay date is typically the business day prior. Because all months are not the same length, the size of the paycheck could vary in that the first paycheck could cover 13-14 days and the second paycheck could cover 15-16 days. To eliminate the variation in the size of the paycheck, specifically for salaried employees, the total yearly salary is evenly divided between 24 payments resulting in the same paycheck amount each time. This division results in 86.67 hours paid in each paycheck and will at times require our payroll partner to adjust the hours allocated downward or upward to equal 86.67. In the rare case that work hours are adjusted upward, the work hours are allocated to the primary funding source for the position. The process has worked traditionally as the Alliance has no hourly employees. Specifically for the three awards referenced, reconciliation between the budget estimates, relative level of effort by percent of full-time employees and active projects, and the hours recorded in the timekeeping system were completed. Staff opted to continue reporting on relative level of effort by percent of full-time employees as opposed to shifting as the timekeeping system was very new and staff experienced a significant learning curve. Additionally, there were only two months left in the grant period. Relative level of effort was carefully documented internally via calendars, Monday.com project management software, and Excel spreadsheets. Since its implementation, staff have been better trained in the use of the timekeeping system. We are also transitioning to a new timekeeping system in December 2024 with enhanced reporting and ease of use. The Alliance will also shift to a bi-weekly payroll period effectively reducing the need to adjust work hour allocations upward or downward to equal 86.67 hours.
Finding 2023-010 – Salaries and Wages (Allowable Costs) Information on Federal Programs: Environmental Finance Center Grants – Assistance Listing No. 66.203 U.S. Environmental Protection Agency Grant No. 539001D, Grant period July 1, 2022 - September 30, 2023 Grant No. 5127620, Grant period October 1, 2022 - September 30, 2023 Grant No. 5126607, Grant period July 1, 2022 - September 30, 2023 Criteria or Specific Requirements: According to 2 CFR Section 200.430(g), charges to Federal grants for salaries and wages must be based on records that accurately reflect the work performed and the records must: a. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b. Be incorporated into the official records of the non-Federal entity; c. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100 percent of compensated activities; d. Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; e. Comply with the established accounting policies and practices of the non-Federal entity; f. Support the distribution of the employee's salary or wages among specific activities or cost objectives 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; and g. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards. Condition: For the period from October 2022 through May 2023, U.S. Water Alliance did not have a timekeeping system in place. A timekeeping system was implemented in June of 2023, that provides for employees to record hours worked for specific cost objectives, including Federal grants. There are limitations to the timekeeping system’s capabilities. One is no availability to run timesheet reports for closed grants after the grant period ends. Second is the need to manually adjust hours transferred from the timekeeping system to the payroll processing system due to semi-monthly payroll processing and the need to have total number of hours equal to 86.67 for salaried employees. For these three awards, budget estimates or relative level of effort by percent of full-time employees and active projects were used throughout the entire grant period, even after the timekeeping system was put in place. No reconciliation between the budget estimates or relative level of effort by percent of full-time employees and active projects and the hours recorded in the timekeeping system was completed even for the period in which the timekeeping system was in place. Cause: A timekeeping system was not implemented until June 2023. Effect: Salary expenditures that are not charged in accordance with the standards referenced above may be questioned or disallowed by the Federal agency. Perspective: Qualitative reports on activities on these three awards indicate there was work performed; however, due to lack of quantitative support for hours charged to the grant, it is unable to be determined whether the number of hours and ultimately dollars charged for personnel costs for these three awards are the actual hours spent on activities for these three awards. Questioned Costs: Undetermined. Repeat Finding: Not applicable. Recommendation: U.S. Water Alliance should utilize the timekeeping system data for reporting personnel costs for all Federal awards. U.S. Water Alliance should also revisit its procedures for transferring data from the timekeeping system to the payroll processing system and ultimately the general ledger, and should implement proper internal controls to ensure that the amount of hours and salary expenditures charged to grants in the general ledger reconcile to the hours reported by the timekeeping system and amounts reported by the payroll processing system. Views of Responsible Officials and Planned Corrective Actions: A new timekeeping system was implemented in June 2023 to allocate work hours specific to cost objectives, including Federal Grants. While there are limitations to the system, the allocations are transferred from the timekeeping system upon supervisor approval to the Prism (HRIS) Portal and used to prepare payment vouchers. From the HRIS system, we can produce labor allocation reports reflecting how the time was originally allocated in the timekeeping system. The US Water Alliance indeed operates on a semi-monthly payroll period. It has allowed the Alliance to have fixed pay dates though they may not fall on the same day of the week each month. If the pay date falls on a weekend or holiday, the pay date is typically the business day prior. Because all months are not the same length, the size of the paycheck could vary in that the first paycheck could cover 13-14 days and the second paycheck could cover 15-16 days. To eliminate the variation in the size of the paycheck, specifically for salaried employees, the total yearly salary is evenly divided between 24 payments resulting in the same paycheck amount each time. This division results in 86.67 hours paid in each paycheck and will at times require our payroll partner to adjust the hours allocated downward or upward to equal 86.67. In the rare case that work hours are adjusted upward, the work hours are allocated to the primary funding source for the position. The process has worked traditionally as the Alliance has no hourly employees. Specifically for the three awards referenced, reconciliation between the budget estimates, relative level of effort by percent of full-time employees and active projects, and the hours recorded in the timekeeping system were completed. Staff opted to continue reporting on relative level of effort by percent of full-time employees as opposed to shifting as the timekeeping system was very new and staff experienced a significant learning curve. Additionally, there were only two months left in the grant period. Relative level of effort was carefully documented internally via calendars, Monday.com project management software, and Excel spreadsheets. Since its implementation, staff have been better trained in the use of the timekeeping system. We are also transitioning to a new timekeeping system in December 2024 with enhanced reporting and ease of use. The Alliance will also shift to a bi-weekly payroll period effectively reducing the need to adjust work hour allocations upward or downward to equal 86.67 hours.
Finding 2023-010 – Salaries and Wages (Allowable Costs) Information on Federal Programs: Environmental Finance Center Grants – Assistance Listing No. 66.203 U.S. Environmental Protection Agency Grant No. 539001D, Grant period July 1, 2022 - September 30, 2023 Grant No. 5127620, Grant period October 1, 2022 - September 30, 2023 Grant No. 5126607, Grant period July 1, 2022 - September 30, 2023 Criteria or Specific Requirements: According to 2 CFR Section 200.430(g), charges to Federal grants for salaries and wages must be based on records that accurately reflect the work performed and the records must: a. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b. Be incorporated into the official records of the non-Federal entity; c. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100 percent of compensated activities; d. Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; e. Comply with the established accounting policies and practices of the non-Federal entity; f. Support the distribution of the employee's salary or wages among specific activities or cost objectives 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; and g. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards. Condition: For the period from October 2022 through May 2023, U.S. Water Alliance did not have a timekeeping system in place. A timekeeping system was implemented in June of 2023, that provides for employees to record hours worked for specific cost objectives, including Federal grants. There are limitations to the timekeeping system’s capabilities. One is no availability to run timesheet reports for closed grants after the grant period ends. Second is the need to manually adjust hours transferred from the timekeeping system to the payroll processing system due to semi-monthly payroll processing and the need to have total number of hours equal to 86.67 for salaried employees. For these three awards, budget estimates or relative level of effort by percent of full-time employees and active projects were used throughout the entire grant period, even after the timekeeping system was put in place. No reconciliation between the budget estimates or relative level of effort by percent of full-time employees and active projects and the hours recorded in the timekeeping system was completed even for the period in which the timekeeping system was in place. Cause: A timekeeping system was not implemented until June 2023. Effect: Salary expenditures that are not charged in accordance with the standards referenced above may be questioned or disallowed by the Federal agency. Perspective: Qualitative reports on activities on these three awards indicate there was work performed; however, due to lack of quantitative support for hours charged to the grant, it is unable to be determined whether the number of hours and ultimately dollars charged for personnel costs for these three awards are the actual hours spent on activities for these three awards. Questioned Costs: Undetermined. Repeat Finding: Not applicable. Recommendation: U.S. Water Alliance should utilize the timekeeping system data for reporting personnel costs for all Federal awards. U.S. Water Alliance should also revisit its procedures for transferring data from the timekeeping system to the payroll processing system and ultimately the general ledger, and should implement proper internal controls to ensure that the amount of hours and salary expenditures charged to grants in the general ledger reconcile to the hours reported by the timekeeping system and amounts reported by the payroll processing system. Views of Responsible Officials and Planned Corrective Actions: A new timekeeping system was implemented in June 2023 to allocate work hours specific to cost objectives, including Federal Grants. While there are limitations to the system, the allocations are transferred from the timekeeping system upon supervisor approval to the Prism (HRIS) Portal and used to prepare payment vouchers. From the HRIS system, we can produce labor allocation reports reflecting how the time was originally allocated in the timekeeping system. The US Water Alliance indeed operates on a semi-monthly payroll period. It has allowed the Alliance to have fixed pay dates though they may not fall on the same day of the week each month. If the pay date falls on a weekend or holiday, the pay date is typically the business day prior. Because all months are not the same length, the size of the paycheck could vary in that the first paycheck could cover 13-14 days and the second paycheck could cover 15-16 days. To eliminate the variation in the size of the paycheck, specifically for salaried employees, the total yearly salary is evenly divided between 24 payments resulting in the same paycheck amount each time. This division results in 86.67 hours paid in each paycheck and will at times require our payroll partner to adjust the hours allocated downward or upward to equal 86.67. In the rare case that work hours are adjusted upward, the work hours are allocated to the primary funding source for the position. The process has worked traditionally as the Alliance has no hourly employees. Specifically for the three awards referenced, reconciliation between the budget estimates, relative level of effort by percent of full-time employees and active projects, and the hours recorded in the timekeeping system were completed. Staff opted to continue reporting on relative level of effort by percent of full-time employees as opposed to shifting as the timekeeping system was very new and staff experienced a significant learning curve. Additionally, there were only two months left in the grant period. Relative level of effort was carefully documented internally via calendars, Monday.com project management software, and Excel spreadsheets. Since its implementation, staff have been better trained in the use of the timekeeping system. We are also transitioning to a new timekeeping system in December 2024 with enhanced reporting and ease of use. The Alliance will also shift to a bi-weekly payroll period effectively reducing the need to adjust work hour allocations upward or downward to equal 86.67 hours.
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.
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.