Criteria: Payroll payments are based on the timecard submitted for work performed, and the approved rate of pay the employee is entitled to. Time and effort requirements are outlined in 2 CFR 200.430. Condition: In testing payroll transactions, there were numerous instances of inadequate documentation for payroll. There were missing approved pay rate forms and lack of supporting documentation for stipends and differentials paid. There were timecards submitted for support of the payroll which were unapproved, mathematically incorrect, and/or which did not agree to the payroll paid. Cause: The lack of formal processes and procedures for payroll documentation paired with the limited oversight of payroll processing resulted in insufficient supporting information for payroll payments made. Effect or potential effect: Internal control over the financial activities of the YWCA New Hampshire is weakened. Failure to maintain accurate supporting documentation for payroll increases the risk employees are over- or under- paid for work performed. Questioned costs: The questioned costs are unknown, as the amount of payroll that could have been inappropriately charged is unable to be recalculated at this time. Context: The YWCA New Hampshire expended in excess of $750,000 in federal awards and assistance during the year ending June 30, 2023 requiring a compliance audit in accordance with the Uniform Guidance. The organization has not required a compliance audit in previous years and management was not aware of the various requirements of the Uniform Guidance. The payroll deficiencies were a systemic problem noted during the audit. Recommendation: Policies and procedures surrounding payroll should be reviewed with all relevant personnel. Rate of pay forms should be maintained for each employee, signed and approved, and updated for any rate changes. Formal pay rates should be established for all shift differentials and stipends. Timecards should be appropriately completed each week, approved, and reviewed during the payroll processing. Views of Responsible Officials: YWCA New Hampshire’s management concurs with this audit finding.
Criteria: Payroll payments are based on the timecard submitted for work performed, and the approved rate of pay the employee is entitled to. Time and effort requirements are outlined in 2 CFR 200.430. Condition: In testing payroll transactions, there were numerous instances of inadequate documentation for payroll. There were missing approved pay rate forms and lack of supporting documentation for stipends and differentials paid. There were timecards submitted for support of the payroll which were unapproved, mathematically incorrect, and/or which did not agree to the payroll paid. Cause: The lack of formal processes and procedures for payroll documentation paired with the limited oversight of payroll processing resulted in insufficient supporting information for payroll payments made. Effect or potential effect: Internal control over the financial activities of the YWCA New Hampshire is weakened. Failure to maintain accurate supporting documentation for payroll increases the risk employees are over- or under- paid for work performed. Questioned costs: The questioned costs are unknown, as the amount of payroll that could have been inappropriately charged is unable to be recalculated at this time. Context: The YWCA New Hampshire expended in excess of $750,000 in federal awards and assistance during the year ending June 30, 2023 requiring a compliance audit in accordance with the Uniform Guidance. The organization has not required a compliance audit in previous years and management was not aware of the various requirements of the Uniform Guidance. The payroll deficiencies were a systemic problem noted during the audit. Recommendation: Policies and procedures surrounding payroll should be reviewed with all relevant personnel. Rate of pay forms should be maintained for each employee, signed and approved, and updated for any rate changes. Formal pay rates should be established for all shift differentials and stipends. Timecards should be appropriately completed each week, approved, and reviewed during the payroll processing. Views of Responsible Officials: YWCA New Hampshire’s management concurs with this audit finding.
Criteria: Time and effort requirements state that employee time must be maintained with sufficient documentation to provide for appropriate allocation to the federal program. Time and effort requirements are outlined in 2 CFR 200.430. 32 Condition: Payroll charges for the grant were based on a percentage of time by employee. This percentage was based on management’s decision and set when budgeting; the percentage charged to the grant was not based on actual hours worked. Cause: Payroll was processed by an outside service provider based on information provided by management. Management did not require the breakdown of hours as it relates to the federal programs which were being charged. Management was unaware of this time and effort requirement. Effect or potential effect: The costs submitted for reimbursement under the grant may not be appropriate. The failure to report time appropriately and allocate by program could increase the risk of errors in amounts reported as expended. Questioned costs: The questioned costs are unknown, as the amount of payroll that could have been inappropriately charged to the grant is unable to be recalculated at this time. The true allocation of hours was not recorded. Context: The YWCA New Hampshire expended in excess of $750,000 in federal awards and assistance during the year ending June 30, 2023 requiring a compliance audit in accordance with the Uniform Guidance. The organization has not required a compliance audit in previous years and management was not aware of the various requirements of the Uniform Guidance. The payroll deficiencies were a systemic problem noted during the audit. Recommendation: We recommend that time and effort be maintained in accordance with the Uniform Guidance. We recommend that employees clearly identify hours by grant program for appropriate allocation of the expenses. Views of Responsible Officials: YWCA New Hampshire’s management concurs with this audit finding.
Condition: The auditee submitted reimbursement requests to the Mississippi Department of Education (MDE) that were not fully supported: Standard monthly amounts requested for Digital Learning Instructor (DLI) labor exceeded actual contract costs, resulting in overstatements. 1 of 60 items sampled lacked support for $11,700 in charges. Cause: The Consortium requested funds before receiving invoices or verifying actual expenses. There was no reconciliation process in place to verify that reimbursement requests matched actual expenditures. Effect: Federal funds were received in excess of allowable costs and not returned to the grantor. These excess reimbursements represent questioned costs which the grantor could request funds to be refunded. Criteria: In accordance with 2 CFR §200.403 and §200.430, costs must be necessary, reasonable, and allocable, and adequately documented to be allowable under federal awards. Questioned Costs: Total known questioned costs are $49,082, which includes: $37,382 related to Digital Learning Instructor (DLI) contract labor, including $34,445 in excess labor charges and $2,937 in related indirect costs. These charges were identified through a 100% review of all DLI contract labor activity for fiscal year 2023. $11,700 from a single reimbursement request that partially lacked supporting documentation. This item was identified during testing of a sample of 60 items totaling $6,545,759.87. Based on this sample, we project likely questioned costs of $16,918, using a non-statistical method. Therefore, total questioned costs are estimated at $54,300. Recommendation: Reimbursement requests should only be submitted after expenses are incurred and documented. The Consortium should wait for invoices before requesting funds, or reconcile estimates to actual costs and return excess funds, and maintain full documentation for all requests. Views of Responsible Officials: The Consortium acknowledges the finding and is working to establish a reconciliation process to identify and return any excess funds, and providing staff training on documentation and cost principles.
2023-002 Payroll Costs Federal Program - U.S. Department of the Treasury – Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal Award Number - SLFRP0136 Compliance Requirement - Allowable Costs/Cost Principles (2 CFR § 200.430) Criteria - Under 2 CFR § 200.430(g), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Compensation for leave must be granted under established leave policies and must be allocable and reasonable for the services rendered. Costs for leave that is not earned or used, or that is forfeited, are generally not allowable under federal awards. Condition - The organization uses a calculated hourly rate to allocate payroll costs to programs. This rate includes a pro rata amount for vacation and sick time earned each pay period. However, the organization’s leave policy does not allow for carryover of unused vacation or sick time. As a result, some of the accrued leave may never be used or paid out but was still charged to federal programs through the calculated rate. Cause - The organization’s methodology for allocating payroll costs does not differentiate between earned and used leave and does not account for the forfeiture of unused time at year-end. Effect - Federal awards may have been charged for leave benefits that were never realized or paid to employees, resulting in an overstatement of payroll costs charged to the program. However, based on our analysis, the financial impact of this condition was not material to the federal award and the estimated questioned costs were below the $25,000 reporting threshold. Questioned Costs - $0. No questioned costs are reported as the estimated impact is below the reporting threshold and not material to the award. Recommendation - We recommend that the organization revise its payroll allocation methodology to ensure only used or vested leave is charged to federal awards. If estimates are used, they should be supported by documentation and periodically reconciled to actual costs. Non-vested leave that may be forfeited should not be included in federally funded rates. Views of Responsible Officials - We agree with the findings and determined it was due to outdated processes and a gap in technical expertise utilizing the payroll allocations within the accounting software.
2023-001 Lack of Documentation to Support Distribution of Wages (Material Weakness) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Education Stabilization Fund Assistance Listing Number: 84.425U Passed-through Identification: #20221232 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the School District, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll expenditures charged to the grant, we noted that one employee who worked solely on a single federal program did not have a completed semi-annual certification on file to support the time and effort charged to the grant. As required by 2 CFR 200.430, charges to federal awards for salaries must be supported by documentation that accurately reflects the work performed. For employees working 100% on a single federal program, this requirement is typically met through semi-annual certifications. Cause: Administrative oversight, turnover of internal staffing. Effect: By not obtaining a completed semi-annual certification for an employee working solely on a federal program, the School District did not comply with federal requirements under 2 CFR 200.430. This lack of documentation diminishes the School District’s ability to demonstrate that salary costs charged to the grant were accurate, allowable, and properly supported, potentially placing the $27,615 in questioned costs at risk of disallowance. Questioned Costs: $27,615 Repeat Finding: No Recommendation: We recommend that the School District implement procedures to ensure that semi-annual certifications are completed and retained for all employees whose salaries are charged 100% to a single federal program. These certifications should be signed by the employee or a supervisory official with firsthand knowledge of the work performed and maintained as part of the School District’s official records to support compliance with 2 CFR 200.430. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College’s supporting documentation did not match to the amount of employee’s pay charged to grant. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause: The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect: Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies. Questioned Costs: Known questioned costs of $6,812 and likely questioned costs of $83,407. Auditor recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts.
2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College’s supporting documentation did not match to the amount of employee’s pay charged to grant. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause: The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect: Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies. Questioned Costs: Known questioned costs of $6,812 and likely questioned costs of $83,407. Auditor recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts.
2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College’s supporting documentation did not match to the amount of employee’s pay charged to grant. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause: The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect: Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies. Questioned Costs: Known questioned costs of $6,812 and likely questioned costs of $83,407. Auditor recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts.
2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College’s supporting documentation did not match to the amount of employee’s pay charged to grant. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause: The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect: Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies. Questioned Costs: Known questioned costs of $6,812 and likely questioned costs of $83,407. Auditor recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
A. Finding on Internal Control over Compliance Finding Reference: 2023-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, where required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2022-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if thless than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
A. Finding on Internal Control over Compliance Finding Reference: 2023-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, where required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2022-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if thless than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost 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. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost 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. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost 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. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost 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. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.