Payroll Allocations Finding Number: 2022-007 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2022 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Noncompliance and Significant Deficiency 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.430 which provides, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees 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. The Authority approved a standard allocation of 64% of administrative salaries to the Housing Choice Voucher (HCV) Program. However, due to a failure of internal controls when a fire at the Authority offices limited staff access to the Office resulting in the Executive Director circumventing established controls to process payroll, one payroll processed during 2022 allocated 100% of salaries to the HCV Program rather than the approved 64%. The total amount posted to HCV in error was $3,348. The Executive Director and Financial Director should ensure that all payroll is correctly allocated by program for every payroll.
Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies 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; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.
Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies 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; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.
Finding: Item 2022-002 – Allowable Costs Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Federal Program – Supportive Housing for Veterans Assistance Listing Number – 64.033 Material Weakness Criteria: 2 CFR §200.430 (8)(i) Compensation – personal services, Standards for Documentation of Personnel Expenses specifies 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; (viii) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that (…) (c) the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition/context: The Council allocates payroll costs to grants primarily based on initial budgets. The Council did not have internal controls established to verify that the employees’ actual work performed did not alter from initial budgeting, which may require an adjustment to costs charged to the grants. Cause: The Council did not have internal controls or processes established to track which programs an employee worked on throughout the year. Effect: Inadequate documentation for payroll allocations increases the risk of inaccurate, unallowable, or wrongly allocated payroll expenses charged to grants, which may result in questioned costs and potential reduction or loss of future funding due to noncompliance. Questioned cost: Questioned costs below are aggregated from the five months tested. Healthy Start Initiative: $157,251 Supportive Housing for Veterans: $446,184 Recommendation: We recommend the Council establish a process and related internal controls to monitor for which programs an employee performs work and adjust any incorrectly allocated grant expenses, if applicable. View of responsible officials: Management’s response is reported in “Corrective Action Plan” at the end of this report.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires nonfederal entities receiving Federal awards to "Establish and maintain internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Criteria: The Association’s procedures for processing expenditures, and primarily allocating expenditures to programs, should include controls that ensure expenditures are properly charged to program and allocated in accordance with the federal grant requirements. The objective of the Assistance Listing 93.600 Head Start program (including Early Head Start and Early Head Start Partnerships) is to promote school readiness of low-income children (including American Indians, Alaska Natives and migrant and seasonal farm workers) by enhancing children’s cognitive, social and emotional development. During the fiscal year ending December 31, 2022, the Association expended $4,546,478 in major program funding. Federal regulations require award recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal regulations require the Association to have adequate time-and-effort documentation to support all payroll costs charged to the Head Start awards. 2 CFR 200.430, Compensation – personal services, states, in part: “(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (ii) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”. Depending on the number and types of activities employees perform, time and effort documentation can be in the form of semi-annual certification or monthly personnel activity reports, such as a timesheet. Condition: The Association’s controls were not effective to ensure it maintained adequate time and effort documentation, as required by federal regulations and the grantor. During review of payroll costs for the year ended December 31, 2022, it was noted payroll costs were charged according to budgeted time rather than reconciling to actual hours worked. This internal control deficiency is considered to be a significant deficiency. Questioned Costs: None. Context: Procedures included examining payroll charges for 40 randomly selected employees for January through December 2022. Cause: The Association changed the software used for payroll processing from QuickBooks to MIP in July 2020. They then changed their fiscal accounting software from QuickBooks to MIP in January 2021. The new software implementation was fraught with many challenges, one of which being implementing electronic processes that met the time and effort requirements outlined in the Association’s policy manual. Effect: By not keeping proper time-and-effort records, the Association cannot demonstrate compliance with grantor’s requirements that require support for payroll costs charged to the federal program. The Association provided alternate documentation that demonstrated the payroll costs charged to the program were allowable. Therefore, we are not questioning costs. Repeat finding: This finding is a repeat finding in the immediately prior year. Prior year finding number 2021-004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Association follow its own documented controls to ensure it prepares adequate time-and-effort documentation to support payroll costs charged to the federal grant. View of Responsible Officials: There is no disagreement with this audit finding.
Criteria: The Association’s procedures for processing expenditures, and primarily allocating expenditures to programs, should include controls that ensure expenditures are properly charged to program and allocated in accordance with the federal grant requirements. The objective of the Assistance Listing 93.600 Head Start program (including Early Head Start and Early Head Start Partnerships) is to promote school readiness of low-income children (including American Indians, Alaska Natives and migrant and seasonal farm workers) by enhancing children’s cognitive, social and emotional development. During the fiscal year ending December 31, 2022, the Association expended $4,546,478 in major program funding. Federal regulations require award recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal regulations require the Association to have adequate time-and-effort documentation to support all payroll costs charged to the Head Start awards. 2 CFR 200.430, Compensation – personal services, states, in part: “(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (ii) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”. Depending on the number and types of activities employees perform, time and effort documentation can be in the form of semi-annual certification or monthly personnel activity reports, such as a timesheet. Condition: The Association’s controls were not effective to ensure it maintained adequate time and effort documentation, as required by federal regulations and the grantor. During review of payroll costs for the year ended December 31, 2022, it was noted payroll costs were charged according to budgeted time rather than reconciling to actual hours worked. This internal control deficiency is considered to be a significant deficiency. Questioned Costs: None. Context: Procedures included examining payroll charges for 40 randomly selected employees for January through December 2022. Cause: The Association changed the software used for payroll processing from QuickBooks to MIP in July 2020. They then changed their fiscal accounting software from QuickBooks to MIP in January 2021. The new software implementation was fraught with many challenges, one of which being implementing electronic processes that met the time and effort requirements outlined in the Association’s policy manual. Effect: By not keeping proper time-and-effort records, the Association cannot demonstrate compliance with grantor’s requirements that require support for payroll costs charged to the federal program. The Association provided alternate documentation that demonstrated the payroll costs charged to the program were allowable. Therefore, we are not questioning costs. Repeat finding: This finding is a repeat finding in the immediately prior year. Prior year finding number 2021-004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Association follow its own documented controls to ensure it prepares adequate time-and-effort documentation to support payroll costs charged to the federal grant. View of Responsible Officials: There is no disagreement with this audit finding.
Criteria: The Association’s procedures for processing expenditures, and primarily allocating expenditures to programs, should include controls that ensure expenditures are properly charged to program and allocated in accordance with the federal grant requirements. The objective of the Assistance Listing 93.600 Head Start program (including Early Head Start and Early Head Start Partnerships) is to promote school readiness of low-income children (including American Indians, Alaska Natives and migrant and seasonal farm workers) by enhancing children’s cognitive, social and emotional development. During the fiscal year ending December 31, 2022, the Association expended $4,546,478 in major program funding. Federal regulations require award recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal regulations require the Association to have adequate time-and-effort documentation to support all payroll costs charged to the Head Start awards. 2 CFR 200.430, Compensation – personal services, states, in part: “(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (ii) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”. Depending on the number and types of activities employees perform, time and effort documentation can be in the form of semi-annual certification or monthly personnel activity reports, such as a timesheet. Condition: The Association’s controls were not effective to ensure it maintained adequate time and effort documentation, as required by federal regulations and the grantor. During review of payroll costs for the year ended December 31, 2022, it was noted payroll costs were charged according to budgeted time rather than reconciling to actual hours worked. This internal control deficiency is considered to be a significant deficiency. Questioned Costs: None. Context: Procedures included examining payroll charges for 40 randomly selected employees for January through December 2022. Cause: The Association changed the software used for payroll processing from QuickBooks to MIP in July 2020. They then changed their fiscal accounting software from QuickBooks to MIP in January 2021. The new software implementation was fraught with many challenges, one of which being implementing electronic processes that met the time and effort requirements outlined in the Association’s policy manual. Effect: By not keeping proper time-and-effort records, the Association cannot demonstrate compliance with grantor’s requirements that require support for payroll costs charged to the federal program. The Association provided alternate documentation that demonstrated the payroll costs charged to the program were allowable. Therefore, we are not questioning costs. Repeat finding: This finding is a repeat finding in the immediately prior year. Prior year finding number 2021-004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Association follow its own documented controls to ensure it prepares adequate time-and-effort documentation to support payroll costs charged to the federal grant. View of Responsible Officials: There is no disagreement with this audit finding.
Finding 2022–001: Internal Controls over Allowable Costs Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.303, Internal controls states “The non-Federal” entity must: (1) establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities…; (v) Comply with the established accounting policies and practices of the non-federal entity…; (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity's written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Condition/Context During the current audit period, CDF did not maintain adequate control over allowable costs related to its federally funded program. Exceptions noted in 11 of 60 tested payroll expenditures: For 11 payroll expenditures tested, we were not provided with any evidence of approval of the payroll allocations. We noted these allocations were based on budget estimates, instead of actual time and effort reporting. Exceptions noted in 23 of 60 non-payroll expenditures tested: For 22 non-payroll expenditures tested, we were not provided with any evidence of approval of the overhead allocations. We reviewed the supporting documentation, and the expenditures are deemed allowable. For one expenditure tested, we were not provided with any supporting documentation to determine if the expenditure was allowable. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to support the approval of expenditure allocations. Effect The failure to maintain adequate documentation to verify that expenditures are properly reviewed and approved and to maintain adequate supporting documentation to ensure all payroll and non-payroll expenditures are reasonable and properly reviewed is a violation of federal regulations, which could result in unallowed costs being charged to the federally funded program. Questioned Costs $4,697 Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all expenditure allocations are properly reviewed and approved and supporting documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Finding 2022–001: Internal Controls over Allowable Costs Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.303, Internal controls states “The non-Federal” entity must: (1) establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities…; (v) Comply with the established accounting policies and practices of the non-federal entity…; (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity's written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Condition/Context During the current audit period, CDF did not maintain adequate control over allowable costs related to its federally funded program. Exceptions noted in 11 of 60 tested payroll expenditures: For 11 payroll expenditures tested, we were not provided with any evidence of approval of the payroll allocations. We noted these allocations were based on budget estimates, instead of actual time and effort reporting. Exceptions noted in 23 of 60 non-payroll expenditures tested: For 22 non-payroll expenditures tested, we were not provided with any evidence of approval of the overhead allocations. We reviewed the supporting documentation, and the expenditures are deemed allowable. For one expenditure tested, we were not provided with any supporting documentation to determine if the expenditure was allowable. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to support the approval of expenditure allocations. Effect The failure to maintain adequate documentation to verify that expenditures are properly reviewed and approved and to maintain adequate supporting documentation to ensure all payroll and non-payroll expenditures are reasonable and properly reviewed is a violation of federal regulations, which could result in unallowed costs being charged to the federally funded program. Questioned Costs $4,697 Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all expenditure allocations are properly reviewed and approved and supporting documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Finding 2022–001: Internal Controls over Allowable Costs Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.303, Internal controls states “The non-Federal” entity must: (1) establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Section 200.430 (i) Standards for Documentation of Personnel Expenses states (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities…; (v) Comply with the established accounting policies and practices of the non-federal entity…; (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity's written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Condition/Context During the current audit period, CDF did not maintain adequate control over allowable costs related to its federally funded program. Exceptions noted in 11 of 60 tested payroll expenditures: For 11 payroll expenditures tested, we were not provided with any evidence of approval of the payroll allocations. We noted these allocations were based on budget estimates, instead of actual time and effort reporting. Exceptions noted in 23 of 60 non-payroll expenditures tested: For 22 non-payroll expenditures tested, we were not provided with any evidence of approval of the overhead allocations. We reviewed the supporting documentation, and the expenditures are deemed allowable. For one expenditure tested, we were not provided with any supporting documentation to determine if the expenditure was allowable. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to support the approval of expenditure allocations. Effect The failure to maintain adequate documentation to verify that expenditures are properly reviewed and approved and to maintain adequate supporting documentation to ensure all payroll and non-payroll expenditures are reasonable and properly reviewed is a violation of federal regulations, which could result in unallowed costs being charged to the federally funded program. Questioned Costs $4,697 Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all expenditure allocations are properly reviewed and approved and supporting documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Federal Award Identification Number: 43CAZ03215 Award Period: January 1, 2022 – December 31, 2022 Type of Finding: Material Weakness in internal control over compliance Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part 200.430(i) states “Cost must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition: Employee change of status forms are not consistently maintained in accordance with applicable requirements. Questioned Costs: None. Context: 5 Employee files that were selected for verification disclosed 4 instances where forms were not available for review. Cause: Employee change of status forms or offer letters were not maintained on file or available for review. Effect: Inability to review employee change of status forms or offer letters limits the ability to verify costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain compliance with allowable costs as required by 2 CFR 200.430. Repeat Finding: Yes Recommendation: Offer letters or employee change of status forms should be maintained on file. We recommend management implement a second layer of review of personnel files. Views of Responsible Official: Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured. This includes hiring documentation and change of status forms for employees.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Federal Award Identification Number: 43CAZ03215 Award Period: January 1, 2022 – December 31, 2022 Type of Finding: Material Weakness in internal control over compliance Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part 200.430(i) states “Cost must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition: Employee change of status forms are not consistently maintained in accordance with applicable requirements. Questioned Costs: None. Context: 5 Employee files that were selected for verification disclosed 4 instances where forms were not available for review. Cause: Employee change of status forms or offer letters were not maintained on file or available for review. Effect: Inability to review employee change of status forms or offer letters limits the ability to verify costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain compliance with allowable costs as required by 2 CFR 200.430. Repeat Finding: Yes Recommendation: Offer letters or employee change of status forms should be maintained on file. We recommend management implement a second layer of review of personnel files. Views of Responsible Official: Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured. This includes hiring documentation and change of status forms for employees.
2022-007 Payroll (Material Weakness) Criteria: Title 2 CFR Part 200 §200.430(g). Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Timesheets were not always obtained and did not include information to support employee time and effort as required by federal regulations. Time records did not always include evidence of review/approval. Additionally, for two employees of 60 tested, differences existed between the approved hourly pay rate and the hourly rate paid per the payroll summary. Cause: As discussed at Finding 2022-005, we noted that no policy exists over the form and content of documentation to support employee time and effort under 2 CFR Part 200. And policies are not in place for the review and approval of payroll transactions. Effect: Payroll records did not comply with federal regulations. Because of the failure to require appropriate documentation and review/approval, there is increased risk that payroll transactions could be inappropriately charged to government programs. Questioned Costs: Not determinable due to limitations in the Organization’s accounting system. Perspective: When timesheets were not obtained, we were able to examine other evidence of time worked (such as emails). Forty of 60 tested had no evidence of approval. Repeat Finding: Yes Recommendation: Procedures should be implemented to require appropriate contemporaneous documentation to support time and effort reporting under 2 CFR Part 200. In addition, procedures should also be implemented to require the review and approval of payroll. Views of Responsible Officials: Management acknowledges the control weaknesses as described above as there was not proper documentation of payroll transactions including evidence of review and approval. The Organization has undertaken a review of its policies and procedures, including consultation of an outside accounting firm to ensure proper control procedures over payroll are implemented.
According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Finding 2022-002: Lack of documentation of review and approval - Material Weakness Program name: Office for Coastal Management Assistance Listing: 11.473 Federal award Identification number: 20 NFWF 339630 Federal award year: 9/1/2020 - 8/31/2023 Federal awarding agency: U.S. Department of Commerce Criteria - In accordance with 2 CFR 200.303, recipients and subrecipients must establish, document and maintain effective internal control over Federal awards. These controls should be in compliance with Federal statutes, regulations, and the terms and conditions of the award, and should align with standards such as the “Standards for Internal Control in the Federal Government” (Green Book) or the COSO framework. This includes controls over: * Payroll: Ensuring labor charges are accurate, allowable, and properly approved (2 CFR 200.430). * Expenses: Ensuring proper documentation and approval. (2 CFR 200.400(d) ) * Reporting: Ensuring financial reports are accurate, complete, and reviewed prior to submission (2 CFR 200.328). Condition - The Organization has limited written processes of certain transaction classes. There was a pervasive lack of documentation of approval over transactions, including payroll, expenses, and reporting. Cause - The Organization did not maintain or consistently apply documentation protocols for internal control reviews. Formal documentation practices were not in place during the audit period. Effect - Lack of documentation as evidence that controls over compliance were being performed. Documentation should be maintained as evidence that sufficient control activities are in place and would effectively prevent or detect and correct noncompliance. Controls must be followed for every transaction and documentation of the control being performed must be maintained. Questioned costs - None identified. Perspective - The deficiency was pervasive across multiple compliance areas and was not isolated to a specific transaction or department. The scope indicates a systemic control weakness during the audit period. Identification of Repeat Findings - This is not a repeat finding. Recommendation - We recommend that the Organization ensure updated policies and procedures are implemented and consistently applied. This includes: * Documented review and approval of all transactions related to payroll, expenses, and reporting. * Maintenance of written evidence supporting such reviews. * Regular training and internal monitoring to ensure control procedures are consistently followed. Management response - See corrective action plan
AL number: 14.231, AL title: Emergency Solutions Grant Program Federal award identification number and year: LAHSA agreements: GT-BH-ABH-021, GT-BH-RTV-001, GT-BH-RTV-002, GT-BH-RTV-003, GT-BH-RTV-004, GT-BH-RTV-009, GT-TLS-N-013, GTRRH- RR-02, GT-CH-WS-001, GT-1878-2102-001 Name of federal agency: U.S. Department of Housing and Urban Development Name of pass-through entity: Los Angeles Homeless Services Authority Repeat finding: No Criteria: wages must be based on records that accurately reflect the work performed. Specifically: - Employees who work 100% on a single federal award must have certifications stating that all time was dedicated to the grant, signed by the employee or a supervisor with firsthand knowledge, prepared at least semi-annually. - Employees whose time is split among multiple activities must maintain time and effort reports reflecting actual hours worked in a manner consistent with 2 CFR §200.430(g)(vi). - All compensation costs charged to federal awards must be supported by appropriate documentation that complies with the federal cost principles. Condition: Employees who charged 100% of their time to the grant lacked required certifications or timecards documenting that their time was spent exclusively on grant-related activities. - In several instances, no timecards were available. - In other cases, available timecards showed no evidence of review or approval. - Timecards did not indicate program activity. - Timecards lacked evidence of supervisor approval. - Employees whose time was allocated to multiple programs had no indication of how their time was allocated on the time card. We did note, however, that most allocated employees were working on multiple contracts within the same Federal program, and that costs were allocated among the programs based on the number of beds in each facility, which appears to be a reasonable methodology. - Salaried employees did not have a method for indicating time worked. Cause: The organization failed to implement adequate internal controls to ensure compliance with federal timekeeping and documentation requirements for personnel expenses. Additionally, there appears to be a lack of understanding of the documentation and certification requirements under 2 CFR Part 200, Subpart E. Effect or potential effect: The lack of proper documentation and certification creates a risk that unallowable costs were charged to the grant. Questioned cost: N/A Recommendation: Develop and implement policies and procedures to ensure that timecards and/or certifications are completed and retained for all employees who charge 100% of their time to the grant. Implement a compliant system of time and effort reporting for employees whose time is allocated across multiple activities to align with 2 CFR §200.430(g)(vi). Conduct training for all employees and supervisors on the requirements for documenting and certifying time and effort for federal grants. Perform periodic reviews of timekeeping records and compensation charges to verify compliance with federal requirements. Views of reponsible officials: During this period, Hope The Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We are also partnering with our new 3rd party payroll provider to set up time allocation for salaried employees.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.
Allowable Activities and Costs for Provider Relief Fund Significant Deficiency in Internal Control Over Compliance Federal Assistance Listing Number: 93.498 COVID-19 – Provider Relief Fund (PRF) Criteria: Per 2 CFR 200.430 (i), personnel costs charged to federal grants are required to be supported by documentation including time records. Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition: Our audit procedures over payroll expenses charged to the PRF federal program disclosed timesheets that were not approved by management prior to payment. Cause: The Hospital has a policy requiring supervisory approval of timesheets. The absence of the proper approval for the timesheets tested appears to be a lack of management oversight. Effect: Unauthorized wages can result from undocumented reviews and approvals of timesheets. Questioned Costs: None Perspective: Seven timesheets in a sample of forty timesheets were not approved by management. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Hospital enforce their policy requiring supervisory review and approval for timesheets to ensure time recorded by employees’ is valid and accurate, and that the salaries and wages paid is for work performed. View of Responsible Officials: See management’s response to the finding in the accompanying Corrective Action Plan.
Finding Type: Noncompliance and material weakness in internal control over compliance (activities allowed or unallowed and allowable costs / cost principles). Program: Continuum of Care: Assistance Listing Number 14.267 Criteria: The Uniform Guidance (Title 2 CFR 200.430) requires that allocations for salaries must be based on records that reflect the work performed. Payroll records (timesheets) must be supported by internal controls that create the environment to ensure that payroll items are charged to activities that are accurate, allowable, and properly allocated. Any necessary adjustments to these items should be made so that the final amount charged to the activities is accurate, allowable, and properly allocated. Condition/Finding: Salaries and wages were allocated using percentages to distribute payroll costs allocated to grants. Costs were not consistently allocated to reflect the activity actually performed in five out of the six payroll cycles that we tested. Cause: The Organization did have a system of controls in place for the fiscal year ending September 30, 2022 requiring employees report time spent in specific areas on their timesheets. However, the control was overridden by management and was not applied on a consistent basis. There were payrolls tested where timesheet was not compared to payroll journals provided by the payroll service, the accounting records, or the reimbursement requests for grants. Effect: Payroll costs reflected in the books and records of the Organization did not agree to the payroll journals, timesheets, and reimbursement requests. This required the Organization to use spreadsheets and calculation to support grant funding requests. Some timesheets were found to be inaccurate, resulting in employee personnel costs being reimbursed without proper documentation. Questioned Costs: The total amount of payroll reimbursed without timecards documenting actual labor charges was $21,326 during the year ended September 30, 2022. Recommendation: We recommend that the Organization improve its financial management policies and procedures to ensure that multiple staff members are involved in the process of reviewing and allocating personnel expenses to grants. Policies and procedures over payroll should include employees entering time accurately across areas where they spent time, supervisory review, recalculation and approval of timesheets, review of timesheets and compiled time reporting before it is sent to the payroll provider and review of the reporting provided after the payroll run. Payroll postings input into the accounting system should accurately reflect time spent in each grant area (class) and grant reporting and reimbursement requests should be prepared using those numbers. View of Responsible Officials (Corrective Action): See corrective action plan.
Finding 2022-004 Program Affected Under the U.S. Department of Health and Human Services - Award Year October 1, 2021 - September 30, 2022: Assistance Listing 93.262 Occupational Safety and Health Program Criteria 2 CFR §200.430(i) specifies that "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..." Condition and Context During our program audit procedures related to the payroll cycle, we noted an internal control deficiency related to allocation of payroll costs among federally funded programs. Management did not perform sufficient review of payroll allocations to identify that some payroll expenses were being recorded in excess of readily available wage and time and effort data. We tested a nonstatistical sample of 13, totaling $100,952 from a population totaling $672,541. Cause and Effect The condition identified was caused by infrequent and periodic review of program-related payroll costs which were reconciled on a biannual basis. This process did not occur on a pay period basis. This resulted in an overstatement of program-related payroll expenses of $6,348. Questioned Costs $6,348 Identification as a Repeat Finding, if Applicable Not applicable. Recommendation We recommend the Organization strengthen controls surrounding program-related record keeping, including increasing the frequency of reconciliations and program wage allocation procedures to match the payroll cycle. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Education Stabilization Fund, the following problems were noted: • Timesheet or payroll service reports for twelve of the fourteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that five of the fourteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for any of the fourteen employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Education Stabilization Fund.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Criteria: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i)Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii)Be incorporated into the official records of the non-Federal entity; (iii)Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv)Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis; (v)Comply with the established accounting policies and practices of the non-Federal entity; (vi)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. Citation: 2 CFR 200.430(i) Condition: Electronic timesheets are maintained for all employees to document time spent on this grant as required by the funder; however, there was no evidence of supervisory review available within the timekeeping system for the period covering October 2021 through May 2022. For the period after May 2022 through August 31, 2022, the review was inconsistently documented. Cause: There was no evidence of the supervisory review to ensure salary expense was distributed to specific Federal awards for the period from October 2021 to May 2022. Effect: There is a risk that the salary of an employee could be distributed to a federal award at an amount that is different than the actual time spent on that Federal program. Context: We reviewed timesheets and noted the entity?s system of internal control was not designed to include a supervisors? review of the accuracy of timesheets to verify that an employees? time was distributed to the program that they spent time on from October 2021 to May 2022. Repeat Finding: Yes Recommendation: We recommend that all timesheets and other electronic records used to track time spent on the program be reviewed by a supervisor and that this review be documented.
Reference Number: 2022-001 Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) 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 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; (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 Commission did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses applied to the federal program. Context: Forty payroll transactions were selected for testing and one of the transactions charged to the grant was not supported by a timesheet. The timesheet was also not approved by a supervisory or independent individual. Questioned costs: The amount charged to the grant for this transaction was $582. Cause: Controls were not operating effectively to ensure that payroll reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. Views of responsible officials: One of our employee?s timesheets was supposed to charge Account #500, but the incorrect formula was used and summed to Account #802 in December. This resulted in $582 difference between the two projects identified as a questioned cost above. By the end of 2022 fiscal year, however, we didn't overcharge project #802. ICPRB expended nearly $80,000 more on this project than was charged to the federal government so this oversight had no effect. This minor error resulted from the termination of our former Admin Director and the resignation of his temporary replacement. Our new Office Manager (hired on February 15, 2023) has assumed the responsibility of reviewing the timesheets so this will not be repeated. In addition, we have decided to block employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software.
Item 2022-001 Written policies, procedures, and standards of conduct Water and Waste Disposal Systems for Rural Communities Assistance Listing Number 10.760 U.S. Department of Agriculture Grant period: Year ended September 30, 2022 Questioned Costs ? $0 Condition ? The Board does not have all of the written policies, procedures and standards of conduct required by UG. Criteria ? Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits Cause of Condition ? The Board has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition ? Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation ? We recommend that the Board implement the required written policies and procedures. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.
2022-001: Controls over the payroll process should be enhanced. Type: Significant deficiency in internal control over compliance Assistance Listing Number, Federal Agency, Program Name, Program Title, Pass-through Grantor, and Pass-through Name and Grant Number: Assistance Listing #93.044, U.S. Department of Health and Human Services, Passed Through Area Agency on Aging, Special Programs for the Aging-Grants for Supportive Services and Senior Centers, Title III, Part B - Chore, 20-9046-C Criteria: Per 2CFR 200.430, personnel expenses that are charged to a federal program must, among other things, be based on records that accurately reflect the work performed. Condition: During our testing of payroll charged to the program, we noted differences between the personal activity reports and the amount charged to the program. Cause: The Council?s calculation of the allocation of wages to the program did not include essential pay or opt-out compensation as part of the hours worked. Context: Four (4) out of seven (7) personal activity reports tested for the Chore program differed from the amount charged to the program. Effect: No financial effect since the Council charges less than 100% of the eligible salaries, wages, and payroll taxes to the Chore program. Recommendation: The control process should be reviewed and modified appropriately so that control would be established to note any differences between the amounts being charged and personal activity reports.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.