Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The 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) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Finding Number 2023-001 Internal Controls over Allowable Activities and Costs Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards for Financial and Program Management Section 200.303, Internal controls states “The nonFederal” entity must: (1) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities…; (v) Comply with the established accounting policies and practices of the non-Federal entity…; (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: As per the grant agreement and the approved budget, there are no approved costs for occupancy and indirect costs. However, we noted during our testing there were a few expenditures related to the allocation of occupancy and national support (indirect costs) which are not allowed per the grant agreement. Additionally, management is charging salary expenses to the grant based on the estimated percentage on a monthly basis. The allocation methodology currently utilized is not supported with proper time and effort records. Cause: Certain controls related to the oversight of compliance are designed and implemented but are not effectively working. Also, evidence of time and effort is not properly documented. Effect: The lack of effective control over compliance resulted in an instance of noncompliance identified. In addition, not maintaining adequate supporting documentation for personnel cost is a violation of federal regulations which could result in unallowed payroll costs being charged to the federally funded program. Questioned Cost: Total expenditure of $13,960.20 did not comply with the compliance requirements. Context: During our review of 12 expenditures, 4 instances were identified where the costs did not meet the eligibility and allowability compliance requirements. During our review of 29 payroll expense items, we noted that payroll expenses charged to the program were based on estimates instead of actual time and effort.
Finding Number 2023-001 Internal Controls over Allowable Activities and Costs Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards for Financial and Program Management Section 200.303, Internal controls states “The nonFederal” entity must: (1) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities…; (v) Comply with the established accounting policies and practices of the non-Federal entity…; (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: As per the grant agreement and the approved budget, there are no approved costs for occupancy and indirect costs. However, we noted during our testing there were a few expenditures related to the allocation of occupancy and national support (indirect costs) which are not allowed per the grant agreement. Additionally, management is charging salary expenses to the grant based on the estimated percentage on a monthly basis. The allocation methodology currently utilized is not supported with proper time and effort records. Cause: Certain controls related to the oversight of compliance are designed and implemented but are not effectively working. Also, evidence of time and effort is not properly documented. Effect: The lack of effective control over compliance resulted in an instance of noncompliance identified. In addition, not maintaining adequate supporting documentation for personnel cost is a violation of federal regulations which could result in unallowed payroll costs being charged to the federally funded program. Questioned Cost: Total expenditure of $13,960.20 did not comply with the compliance requirements. Context: During our review of 12 expenditures, 4 instances were identified where the costs did not meet the eligibility and allowability compliance requirements. During our review of 29 payroll expense items, we noted that payroll expenses charged to the program were based on estimates instead of actual time and effort.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241, 14.267 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved. • For Housing Opportunities for Persons with AIDS: o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized. o 1 out of 60 selections did not maintain a timesheet allocation. o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations. o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized. • For the Continuum of Care Program: o 4 out of 83 selections did not maintain a timesheet allocation. o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized. o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked. Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors. Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: Housing Opportunities for Persons with AIDS Known Questioned Costs: $881 Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747 Continuum of Care Program Known Questioned Costs: $869 Continuum of Care Program Likely Questioned Costs: $144,388 Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs. Identification as a Repeat Finding: 2022-010, 2022-017 Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527 Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…” Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors. Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations. Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324. Identification as a Repeat Finding: 2022-009 Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs. Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527 Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement. • For Health Center Program Cluster: o 72 out of 79 selections did not have timely completion of attestations. • For the Continuum of Care Program: o 1 out of 56 selections did not have timely completion of attestations. Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged. Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant. Questioned Costs: None reported. Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469. Identification as a Repeat Finding: 2022-004. Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments. Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Program Titles – Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing No. – 93.243 Federal Agencies – U.S. Department of Health and Human Services Federal Award Numbers – S23-SM84816-027 Grant Award Periods – April 1, 2023 – September 29, 2023 Compliance Requirements – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: Costs of compensation are allowable to the extent that they satisfy the specific requirements of 2 CFR 200.430, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with entity’s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported (documented) as provided in 2 CFR 200.430 (i), when applicable. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other things, these records must: • Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities. – 2 CFR 200.430(i)(1)(iii) • Comply with the established accounting policies and practices of the non-federal entity. – 2 CFR 200.430(i)(1)(v) • Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. – 2 CFR 200.430(i)(1)(vii)Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: – The system for establishing the estimates produces reasonable approximations of the activity actually performed; – Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and – The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Conditions Found: Compensation charges were charged to ALN 93.243, and included $828,602 of salaries and fringes that were allocated to the grant based on budget estimates to time spent by the employees. Boys Town has policies that require a certification process to affirm after-the-fact the allocation based on budget estimates were appropriate or require adjustment in the accounting records. Boys Town policies require effort reports for monthly, quarterly, and annual time periods. Completion and certification must occur no later than 60 days from the end of the time period that is being certified. On January 1, 2023, Boys Town implemented a new enterprise resource planning system, Workday, which included human resources and payroll processing. Workday has an effort reporting business process built into its functionality. However, since the implementation of Workday, no certifications have been performed. As part of monthly invoicing to grantor under ALN 93.243, details of employees and their percentage of time allocated is included in the invoicing package. This monthly invoice is reviewed by program manager. Questioned Cost: Question costs is not determinable. Cause and Effect: In discussing these conditions with Boys Town management, there were issues with the system implementation that required re-allocation of payroll that were not finalized until March 2024. This led to delays in initiating the effort certification process in Workday to ensure accurate information could be certified. Repeat Finding: A similar finding was not reported in prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend Boys Town to enhance its internal control process to ensure Boys Town has effective internal controls in place to ensure Boys Town is complying with internal policies and obtaining after-the-fact affirmations for compensation allocated to federal awards. View of Responsible Official: We agree with the conclusions in the finding. Management has already taken corrective action to retroactively obtain certifications for time and effort for the year ended December 31, 2023 and through September 30, 2024. In addition, a process has been implemented to allow certifications to occur in accordance with our policies for the remainder of the fiscal year.