2023-003 – Allowable Costs/Cost Principles Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Substance Use Disorder Residential Treatment for Pregnant and Postpartum Women Assistance listing number: 93.243 Award year: 9/30/2018 – 9/29/2023 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award, and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support disbursements were not maintained for the program. We specifically noted the following: • SFRC is currently allocating payroll costs to the program based on budget estimates. There is not a process in place to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. • For one month during fiscal year 2023, the amounts charged to the program were not supported by wages paid to the employee (used as the basis for the amount allocated to the program). • For two of six non-payroll disbursements tested, the amount allocated to the program did not agree to the amount paid to the vendor. • Indirect costs charged to the program were not allocated correctly based on SFRC’s approved indirect cost rate. Context: 15 of 15 payroll transactions tested were allocated to the program based on budget estimates. Two of six non-payroll disbursements did not agree with source documentation. Questioned Costs: $33,429 Cause: SFRC has not developed a process to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. There was not adequate review of reimbursement requests to ensure that payroll and non-payroll disbursements agree with source documentation. Indirect costs were not charged to the program using the approved indirect cost rate for fiscal year 2023. Effect: SFRC may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendation: SFRC should implement a process of comparing actual time and effort of employees to SFRC’s budget estimates at least bi-annually. Alternatively, SFRC could require employees to report their actual daily time on federal awards to ensure amounts charged are accurate and properly allocated. SFRC should implement a review process of reimbursement requests to ensure that disbursements agree with source documentation, and that indirect costs are charged to the program accurately. Management’s Response: Management implemented a process to evaluate time spent each month. That allocation is used to classify actual salary paid to particular federal awards on a pay period basis.
Reference Number: 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster Assistance Listing Number: 14.218 Award Number and Period: B-22-UC-24-0011, B-20-UW-24-0011 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a 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 statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply 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). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 1 of 40 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $1,260 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster Assistance Listing Number: 14.218 Award Number and Period: B-22-UC-24-0011, B-20-UW-24-0011 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a 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 statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply 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). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 1 of 40 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $1,260 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-006 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19-Emergency Rental Assistance Assistance Listing Number: 21.023 Award Number and Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect work performed. These records must: I. Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a 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 statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply 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). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 7 of 60 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $11,045 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Department of Health and Human Services, Assistance Listing No. 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, 1H79SM083255‐01, 2/15/2022 – 2/14/2023; Assistance Listing No. 93.696, Certified Community Behavioral Health Clinics Expansion Grants, 1H79SM087079‐ 01/1H79SM087007‐01, 9/30/2022 – 9/29/2023 Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.430(i), Standards for Documentation of Personnel Expenses) as it relates to federal grants: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non‐Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally‐assisted and all other activities compensated by the non‐ Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non‐Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non‐Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR Part 200, OMB Compliance Supplement, defines Level of Effort as follows: Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non‐federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non‐federal funding of services Condition: The Center could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support allowable costs or that the level of effort requirements, as outlined in the grant contracts, were achieved. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective activities or federal programs. As a result, certain expenditures were inappropriately claimed as program expenditures, but could not be substantiated for purposes of allowable costs or level of effort. Effect: The Center is at risk for noncompliance with allowable activities and allowable costs, as well as level of effort requirements. Questioned costs: $872,088 in payroll was identified as allowable costs for Section 223, Demonstration Programs to Improve Community Mental Health Services, which could not be substantiated. $1,187,041 in payroll was identified as allowable costs for Certified Community Behavioral Health Clinics Expansion Grants, which could not be substantiated. Context: A nonstatistical sampling of 40 out of over 14,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Section 223, Demonstration Programs to Improve Community Mental Health Services, which accounted for $114,123 of $1,187,041 total program expenditures. 2 of 2 employees were tested with respect to level of effort requirements as outlined in the program contract, but supporting information could not be provided. A nonstatistical sampling of 25 out of 206 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Certified Community Behavioral Health Clinics Expansion Grants, which accounted for $139,829 of $910,628 total program expenditures. 4 of 4 employees were tested with respect to level of effort requirements as outlined in the program contracts, but supporting information could not be provided. Repeat Finding From Prior Year: No Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Views of Responsible Officials: We agree with the finding. See additional response in the Corrective Action Plan.
Department of Health and Human Services, Assistance Listing No. 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, 1H79SM083255‐01, 2/15/2022 – 2/14/2023; Assistance Listing No. 93.696, Certified Community Behavioral Health Clinics Expansion Grants, 1H79SM087079‐ 01/1H79SM087007‐01, 9/30/2022 – 9/29/2023 Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.430(i), Standards for Documentation of Personnel Expenses) as it relates to federal grants: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non‐Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally‐assisted and all other activities compensated by the non‐ Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non‐Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non‐Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR Part 200, OMB Compliance Supplement, defines Level of Effort as follows: Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non‐federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non‐federal funding of services Condition: The Center could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support allowable costs or that the level of effort requirements, as outlined in the grant contracts, were achieved. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective activities or federal programs. As a result, certain expenditures were inappropriately claimed as program expenditures, but could not be substantiated for purposes of allowable costs or level of effort. Effect: The Center is at risk for noncompliance with allowable activities and allowable costs, as well as level of effort requirements. Questioned costs: $872,088 in payroll was identified as allowable costs for Section 223, Demonstration Programs to Improve Community Mental Health Services, which could not be substantiated. $1,187,041 in payroll was identified as allowable costs for Certified Community Behavioral Health Clinics Expansion Grants, which could not be substantiated. Context: A nonstatistical sampling of 40 out of over 14,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Section 223, Demonstration Programs to Improve Community Mental Health Services, which accounted for $114,123 of $1,187,041 total program expenditures. 2 of 2 employees were tested with respect to level of effort requirements as outlined in the program contract, but supporting information could not be provided. A nonstatistical sampling of 25 out of 206 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Certified Community Behavioral Health Clinics Expansion Grants, which accounted for $139,829 of $910,628 total program expenditures. 4 of 4 employees were tested with respect to level of effort requirements as outlined in the program contracts, but supporting information could not be provided. Repeat Finding From Prior Year: No Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Views of Responsible Officials: We agree with the finding. See additional response in the Corrective Action Plan.
Department of Health and Human Services, Assistance Listing No. 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, 1H79SM083255‐01, 2/15/2022 – 2/14/2023; Assistance Listing No. 93.696, Certified Community Behavioral Health Clinics Expansion Grants, 1H79SM087079‐ 01/1H79SM087007‐01, 9/30/2022 – 9/29/2023 Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.430(i), Standards for Documentation of Personnel Expenses) as it relates to federal grants: (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non‐Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally‐assisted and all other activities compensated by the non‐ Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non‐Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non‐Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR Part 200, OMB Compliance Supplement, defines Level of Effort as follows: Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non‐federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non‐federal funding of services Condition: The Center could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support allowable costs or that the level of effort requirements, as outlined in the grant contracts, were achieved. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective activities or federal programs. As a result, certain expenditures were inappropriately claimed as program expenditures, but could not be substantiated for purposes of allowable costs or level of effort. Effect: The Center is at risk for noncompliance with allowable activities and allowable costs, as well as level of effort requirements. Questioned costs: $872,088 in payroll was identified as allowable costs for Section 223, Demonstration Programs to Improve Community Mental Health Services, which could not be substantiated. $1,187,041 in payroll was identified as allowable costs for Certified Community Behavioral Health Clinics Expansion Grants, which could not be substantiated. Context: A nonstatistical sampling of 40 out of over 14,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Section 223, Demonstration Programs to Improve Community Mental Health Services, which accounted for $114,123 of $1,187,041 total program expenditures. 2 of 2 employees were tested with respect to level of effort requirements as outlined in the program contract, but supporting information could not be provided. A nonstatistical sampling of 25 out of 206 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles, in Certified Community Behavioral Health Clinics Expansion Grants, which accounted for $139,829 of $910,628 total program expenditures. 4 of 4 employees were tested with respect to level of effort requirements as outlined in the program contracts, but supporting information could not be provided. Repeat Finding From Prior Year: No Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Views of Responsible Officials: We agree with the finding. See additional response in the Corrective Action Plan.
2023‐004 – Activities Allowed, Allowable Costs over Payroll (Material Noncompliance, Material Weakness over Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF‐SWG‐3‐35‐0037‐057‐2021 Federal Award Year: 2023 Condition: During reconciliation of the general ledger to the SEFA, it was noted multiple pay periods were duplicated which were included in request for reimbursement. 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(f) – Factors affecting allowability of costs ‐ Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $86,333 Effect: The City requested reimbursement for duplicate transactions resulting in disallowed costs.
2023‐004 – Activities Allowed, Allowable Costs over Payroll (Material Noncompliance, Material Weakness over Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF‐SWG‐3‐35‐0037‐057‐2021 Federal Award Year: 2023 Condition: During reconciliation of the general ledger to the SEFA, it was noted multiple pay periods were duplicated which were included in request for reimbursement. 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(f) – Factors affecting allowability of costs ‐ Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $86,333 Effect: The City requested reimbursement for duplicate transactions resulting in disallowed costs.
2023‐004 – Activities Allowed, Allowable Costs over Payroll (Material Noncompliance, Material Weakness over Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF‐SWG‐3‐35‐0037‐057‐2021 Federal Award Year: 2023 Condition: During reconciliation of the general ledger to the SEFA, it was noted multiple pay periods were duplicated which were included in request for reimbursement. 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(f) – Factors affecting allowability of costs ‐ Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $86,333 Effect: The City requested reimbursement for duplicate transactions resulting in disallowed costs.
2023‐004 – Activities Allowed, Allowable Costs over Payroll (Material Noncompliance, Material Weakness over Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF‐SWG‐3‐35‐0037‐057‐2021 Federal Award Year: 2023 Condition: During reconciliation of the general ledger to the SEFA, it was noted multiple pay periods were duplicated which were included in request for reimbursement. 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(f) – Factors affecting allowability of costs ‐ Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $86,333 Effect: The City requested reimbursement for duplicate transactions resulting in disallowed costs.
Reference Number: 2023-010 Prior Year Finding: 2022-012 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV357862155525 (10/1/2020 – 12/31/2022), DV378592255525 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: Combination codes are used by employees to allocate and certify hours worked to Federal grants and employees’ supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system defaults to budgeted grant allocations entered into the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). Sixty timesheets were selected for testing for the WIOA Cluster. Two of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. Sixty timesheets were selected for testing for the Employment Service Cluster (ESC). The following exceptions were noted: • Seven of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. • Two of sixty employee timesheets selected for testing charged costs to the program that did not relate to the ESC grant program. Cause: The Department’s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Noncompliance occurred as payroll charges allocated to the grants were not reflective of actual activity for which the employees were compensated. Additionally, unallowable costs were charged to the ESC grant program through the use of combination codes not associated with the program. Questioned costs: WIOA: Undetermined amount related to budgeted combination codes. ESC: $5,524, the amount charged to an unallowable combination code. Undetermined amount related to budgeted combination codes. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-010 Prior Year Finding: 2022-012 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV357862155525 (10/1/2020 – 12/31/2022), DV378592255525 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: Combination codes are used by employees to allocate and certify hours worked to Federal grants and employees’ supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system defaults to budgeted grant allocations entered into the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). Sixty timesheets were selected for testing for the WIOA Cluster. Two of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. Sixty timesheets were selected for testing for the Employment Service Cluster (ESC). The following exceptions were noted: • Seven of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. • Two of sixty employee timesheets selected for testing charged costs to the program that did not relate to the ESC grant program. Cause: The Department’s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Noncompliance occurred as payroll charges allocated to the grants were not reflective of actual activity for which the employees were compensated. Additionally, unallowable costs were charged to the ESC grant program through the use of combination codes not associated with the program. Questioned costs: WIOA: Undetermined amount related to budgeted combination codes. ESC: $5,524, the amount charged to an unallowable combination code. Undetermined amount related to budgeted combination codes. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-010 Prior Year Finding: 2022-012 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV357862155525 (10/1/2020 – 12/31/2022), DV378592255525 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: Combination codes are used by employees to allocate and certify hours worked to Federal grants and employees’ supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system defaults to budgeted grant allocations entered into the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). Sixty timesheets were selected for testing for the WIOA Cluster. Two of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. Sixty timesheets were selected for testing for the Employment Service Cluster (ESC). The following exceptions were noted: • Seven of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. • Two of sixty employee timesheets selected for testing charged costs to the program that did not relate to the ESC grant program. Cause: The Department’s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Noncompliance occurred as payroll charges allocated to the grants were not reflective of actual activity for which the employees were compensated. Additionally, unallowable costs were charged to the ESC grant program through the use of combination codes not associated with the program. Questioned costs: WIOA: Undetermined amount related to budgeted combination codes. ESC: $5,524, the amount charged to an unallowable combination code. Undetermined amount related to budgeted combination codes. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-010 Prior Year Finding: 2022-012 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV357862155525 (10/1/2020 – 12/31/2022), DV378592255525 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: Combination codes are used by employees to allocate and certify hours worked to Federal grants and employees’ supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system defaults to budgeted grant allocations entered into the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). Sixty timesheets were selected for testing for the WIOA Cluster. Two of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. Sixty timesheets were selected for testing for the Employment Service Cluster (ESC). The following exceptions were noted: • Seven of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. • Two of sixty employee timesheets selected for testing charged costs to the program that did not relate to the ESC grant program. Cause: The Department’s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Noncompliance occurred as payroll charges allocated to the grants were not reflective of actual activity for which the employees were compensated. Additionally, unallowable costs were charged to the ESC grant program through the use of combination codes not associated with the program. Questioned costs: WIOA: Undetermined amount related to budgeted combination codes. ESC: $5,524, the amount charged to an unallowable combination code. Undetermined amount related to budgeted combination codes. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-010 Prior Year Finding: 2022-012 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV357862155525 (10/1/2020 – 12/31/2022), DV378592255525 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: Combination codes are used by employees to allocate and certify hours worked to Federal grants and employees’ supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system defaults to budgeted grant allocations entered into the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). Sixty timesheets were selected for testing for the WIOA Cluster. Two of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. Sixty timesheets were selected for testing for the Employment Service Cluster (ESC). The following exceptions were noted: • Seven of sixty employee timesheets selected for testing did not use combination codes and the employee’s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee’s actual time and effort on the program. • Two of sixty employee timesheets selected for testing charged costs to the program that did not relate to the ESC grant program. Cause: The Department’s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Noncompliance occurred as payroll charges allocated to the grants were not reflective of actual activity for which the employees were compensated. Additionally, unallowable costs were charged to the ESC grant program through the use of combination codes not associated with the program. Questioned costs: WIOA: Undetermined amount related to budgeted combination codes. ESC: $5,524, the amount charged to an unallowable combination code. Undetermined amount related to budgeted combination codes. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2023-034 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Public Health (DPH) Department: Dukes County Sheriff’s Office Federal Program: Opioid-STR Assistance Listing Number: 93.788 Award Number and Year: 1H79TI083328 (9/30/2020 – 9/29/2021) 5H79TI083328 (9/30/2021 – 9/29/2022) 6H79TI083328 (9/30/2021 – 9/29/2023) 1H79TI085778 (9/30/2021 – 9/29/2023) Compliance Requirement: Allowable Cost/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: 2 CFR Section 200.430(I)(1) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) Reserved (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Dukes County Sheriff’s Office (Department) was unable to provide supporting documentation for salaries and wages charged to the program and charged salaries and wages to the program that did not agree with supporting documentation. Context: Forty timesheets were selected for testing and the following exceptions were noted: • For 1 of 40 timesheets, the Department was unable to provide documentation that the timesheet had been reviewed and approved by the employee’s supervisor. • For 2 of 40 timesheets, the Department was unable to provide supporting documentation for the time and effort charged to the program. • For 4 of 40 timesheets, 100% of the employees’ time and effort was charged to the program, but supporting documentation indicated that actual time worked on the program was less than 100%. Questioned costs: $7,587, which represents the amount charged to the program for which supporting documentation was unavailable. $5,383, which represents the difference between the supporting documentation and the amounts charged to the program. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed and documented in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: We recommend the Department enhance its procedures and internal controls, perform additional training over time and effort reporting, and ensure that documentation is maintained and readily available for audit. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: Management agrees with the finding.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
Criteria 2 CFR 200.303 establish that 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and/ or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend on the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it's been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from the agency. Prior Year Audit Finding 2022-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials The PRDOH agrees with the finding. However, PRDOH has implemented several corrective actions. The PRDOH established an internal control to ensure that the required documents are recorded in the files. The Director of Human Resources presented a work plan, in order to implement an effective procedure for reviewing files. A control sheet of documents required to the active records was established in which the Human Resources Officers of the regions and Hospital were requested to verify the employee's files for the required documentation that is need it in the files. Responsible Officials Ledo. Luis Rivera Villanueva Mrs. Luz S. Ramos Pedroza Mrs. Maribel Zayas Estimated Completion Date Sec. Auxiliar de Recursos Humanos Specialist Payroll Officer Director 787-765-2929 ext. 4273 787-765-2929 ext. 4273 787-765-2929 ext. 4209 Implementation is expected to be completed on or before the end of October 2024.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2023-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022, 2022-2023 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022, 2022-2023 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in the Association charging the same compensation to multiple awards. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $7,660 for FALN 10.561, $5,179 for FALN 14.231 Likely Questioned Costs: $63,347 for FALN 10.561, $26,971 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: Yes, this is a repeat of 2022-002. Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Material Weakness in Internal Control over Compliance with Federal Awards and Material Noncompliance Criteria: The Organization should have effective internal controls in place over tracking of employee time to federal grants and contracts, for the Activities allowed/Allowable costs compliance requirement, per 2 CFR 200.430(i). Condition: During the FY 2023 audit, it was noted that while employee timesheets were maintained, the timesheets did not document time allocable to federal programs for Q1 and the first month of Q2 (October 2022). Rather, timesheets related to the federal program reflected a percentage allocation equal to or less than the approved budget. Context: Out of the 25 samples that were tested, 9 did not have proper coding in the timesheet. The sample was not intended to be, and was not, a statistically valid sample. Cause/Effect: Internal control processes over payroll did not detect that employee timesheets did not appropriately capture time specifically chargeable to federal programs. Questioned Costs: $82,253, which was comprised of payroll charges to BEN TANF program for the time allocable to federal programs for Q1 and the first month of Q2 (October 2022). Identification of Repeat Finding: Repeat Finding 2022-001 Recommendation: We recommend that Cornerstones implements a system to properly track time charged to federal programs. In addition, we recommend that management implements internal controls to review and ensure that employee timesheets possess contemporaneous documentation of time spent on individual federal programs. Timesheets should be reviewed and approved in writing by employees’ supervisors. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
Department of Health and Human Services Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558 Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054 Type of Finding: Material Weakness in Internal Control over Compliance with Federal Awards and Material Noncompliance Criteria: The Organization should have effective internal controls in place over tracking of employee time to federal grants and contracts, for the Activities allowed/Allowable costs compliance requirement, per 2 CFR 200.430(i). Condition: During the FY 2023 audit, it was noted that while employee timesheets were maintained, the timesheets did not document time allocable to federal programs for Q1 and the first month of Q2 (October 2022). Rather, timesheets related to the federal program reflected a percentage allocation equal to or less than the approved budget. Context: Out of the 25 samples that were tested, 9 did not have proper coding in the timesheet. The sample was not intended to be, and was not, a statistically valid sample. Cause/Effect: Internal control processes over payroll did not detect that employee timesheets did not appropriately capture time specifically chargeable to federal programs. Questioned Costs: $82,253, which was comprised of payroll charges to BEN TANF program for the time allocable to federal programs for Q1 and the first month of Q2 (October 2022). Identification of Repeat Finding: Repeat Finding 2022-001 Recommendation: We recommend that Cornerstones implements a system to properly track time charged to federal programs. In addition, we recommend that management implements internal controls to review and ensure that employee timesheets possess contemporaneous documentation of time spent on individual federal programs. Timesheets should be reviewed and approved in writing by employees’ supervisors. Views of Responsible Officials and Correction Action: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.425 - Education Stabilization Fund ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.303, 2 CFR 200.430(i) Condition: During audit procedures, it was identified that the school department does not follow a consistent, documented method to ensure employees were paid the proper amount ensuring that only allowable costs are being charged to the program. Cause: The school department does not have the necessary internal controls over compliance. Effect: The school department is at an increased risk for unallowable cost to be charged to the program. Identification of Questioned Costs: None identified. Context: The population for the test consisted of transactions of 121 payroll expenditures. 79 payroll samples were selected using the haphazard method. Of the 79 samples, we identified issues with 17 payroll charges. One employee contract accounted for 11 of those charges. The contract did not accurately describe the employee’s classification. The remaining 6 of the 17 payroll charges had insufficient documentation to support the amount paid. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the school department develop and implement internal policies and procedures to ensure that sufficient documentation to support the charge and to ensure that only allowable costs are charged to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-002 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i) Condition: During the audit process it was identified that the School Department did not maintain sufficient documentation that reflected the work performed. Cause: The school department does not have the necessary internal controls over compliance. Effect: This School Department does not have records that reflect an accurate account of the employee’s time and effort devoted to the program, which could have allowed incorrect amounts to be charged to the grant. Identification of Questioned Costs: None identified. Context: The population for the test consisted of 53 payroll expenditures. We tested 18 out of 21 employees. The School Department completed time and effort certifications for all employees; however, the following issues were identified. 18 employees did not have the proper documentation for the distribution of their wages. The entity’s internal control noted that the direct supervisor overseeing the work completed should sign the documentation, where in these cases the superintendent signed. The documentation for 7 out of the 18 employees time and effort certifications were signed prior to the work being completed and the documentation for 2 out of the 18 employees noted an incorrect percentage charged to the grant. This is not a statistically valid sample. Repeat Finding: This is a repeat finding of 2022-001. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee’s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.
2023-002 - Allowable Costs/Cost Principles Federal Program Information: Department of Education - Passed through the Maine Department of Education: ALN: - 84.010 - Title I - Grants to Local Educational Agencies Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i) Condition: During the audit process it was identified that the School Department did not maintain sufficient documentation that reflected the work performed. Cause: The school department does not have the necessary internal controls over compliance. Effect: This School Department does not have records that reflect an accurate account of the employee’s time and effort devoted to the program, which could have allowed incorrect amounts to be charged to the grant. Identification of Questioned Costs: None identified. Context: The population for the test consisted of 53 payroll expenditures. We tested 18 out of 21 employees. The School Department completed time and effort certifications for all employees; however, the following issues were identified. 18 employees did not have the proper documentation for the distribution of their wages. The entity’s internal control noted that the direct supervisor overseeing the work completed should sign the documentation, where in these cases the superintendent signed. The documentation for 7 out of the 18 employees time and effort certifications were signed prior to the work being completed and the documentation for 2 out of the 18 employees noted an incorrect percentage charged to the grant. This is not a statistically valid sample. Repeat Finding: This is a repeat finding of 2022-001. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee’s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Millinocket School Department.