2022-001 Noncompliance and Internal Controls over Compliance with Cost Principles ? Compensation ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430(i)(1)(viii) states budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition and Context ? Audit procedures revealed that there was a lack of clear documentation to support the actual hours that were allocated or expensed to each agreement. Cause ? The Association?s internal policy states all time entries are to reflect the time actually spent performing assigned duties on each job. In practice, the Association records payroll expenses by award based on an estimate with a set number of hours allocated per week to each award. Actual payroll hours expensed to the grant were not tracked. Effect ? The Association was not in compliance with financial management standards for maintaining payroll expenditure supporting documentation. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over payroll recording and documentation to ensure compliance with Uniform Administrative Requirements, as well as their own time entry policies. Views of Responsible Officials and Planned Corrective Actions ? Senior management has reviewed the Association?s policies for payroll time with the full management team. The Association will continue to use an estimate for payroll hours expensed to awards, but will also record or track actual hours and consider the need for a subsequent adjustment.
2022-001 Noncompliance and Internal Controls over Compliance with Cost Principles ? Compensation ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430(i)(1)(viii) states budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition and Context ? Audit procedures revealed that there was a lack of clear documentation to support the actual hours that were allocated or expensed to each agreement. Cause ? The Association?s internal policy states all time entries are to reflect the time actually spent performing assigned duties on each job. In practice, the Association records payroll expenses by award based on an estimate with a set number of hours allocated per week to each award. Actual payroll hours expensed to the grant were not tracked. Effect ? The Association was not in compliance with financial management standards for maintaining payroll expenditure supporting documentation. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over payroll recording and documentation to ensure compliance with Uniform Administrative Requirements, as well as their own time entry policies. Views of Responsible Officials and Planned Corrective Actions ? Senior management has reviewed the Association?s policies for payroll time with the full management team. The Association will continue to use an estimate for payroll hours expensed to awards, but will also record or track actual hours and consider the need for a subsequent adjustment.
2022-001 Noncompliance and Internal Controls over Compliance with Cost Principles ? Compensation ? 93.569 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430(i)(1)(viii) states budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition and Context ? Audit procedures revealed that there was a lack of clear documentation to support the actual hours that were allocated or expensed to each agreement. Cause ? The Association?s internal policy states all time entries are to reflect the time actually spent performing assigned duties on each job. In practice, the Association records payroll expenses by award based on an estimate with a set number of hours allocated per week to each award. Actual payroll hours expensed to the grant were not tracked. Effect ? The Association was not in compliance with financial management standards for maintaining payroll expenditure supporting documentation. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over payroll recording and documentation to ensure compliance with Uniform Administrative Requirements, as well as their own time entry policies. Views of Responsible Officials and Planned Corrective Actions ? Senior management has reviewed the Association?s policies for payroll time with the full management team. The Association will continue to use an estimate for payroll hours expensed to awards, but will also record or track actual hours and consider the need for a subsequent adjustment.
Program: Shuttered Venue Operations Program Assisting Lister Number: 59.075 Federal Grantor: U.S. Small Business Administration Passed-through: N/A Award No. and Year: SBAHQ21SV002930.2 and 2022 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: 2 CFR 200.430(i), Standards for Documentation of Personnel Expenses, states that charges to Federal awards for salaries and wage records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of the Foundation?s compliance with the Activities Allowed or Unallowed, and Allowable Costs/Costs Principles compliance requirements, we noted that in 37 of 40 payroll program expenditures selected, the employee?s timecard was not approved by a supervisor. Cause: The Foundation?s procedures did not consistently ensure that the review of timecards was documented. Effect: Lack of review and approval for personnel hours could lead to unallowable activities and costs to be charged to the Federal program. Questioned Costs: No questioned costs were identified as a result of our procedures. Repeat Finding from Prior Years: N/A ? First year of Single Audit. Recommendation: We recommend that the Foundation modify and strengthen its current policies and procedures to ensure that all timecards consistently document evidence of approval. The procedures should also address the compensating controls for circumstances where obtaining a supervisor?s approval is not possible. View of Responsible Officials: Management agrees and has designed controls for the supervisor to approve the timecards and ensure the costs are allowable costs.
Item: 2022-004 Assistance Listing Number: 14.241 Programs: Housing Opportunities for Persons with AIDS Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 144347 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? June 30, 2023 Compliance Requirement: Allowable Activities and Costs Criteria: Under cost principles established by 2 CFR 200.430, compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Condition: In our sampling of payroll expenditures charged to the program, we noted one employee's wage rate charged to the grant was not updated consistent with the employee's wage rate increase paid in their payroll. As a result, the incorrect amount of payroll costs was charged to the program (undercharged). Questioned Costs: n/a Context: In a population of over 250 payroll costs charged to the program, we conducted a non-statistical sample of 40 payroll costs charged to the program. In our sample of 40, we noted 2 of 40 payroll selections did not reflect the correct pay rate charged to the program. We noted the program was charged with an old wage rate that was lower than the actual paid rate. As a result, the program was undercharged. This is deemed to be a material weakness in internal control over compliance. Effect: The program was undercharged payroll costs totaling approximately $9. Cause: Southwest Behavioral Health Services, Inc. and Subsidiaries did not have adequate controls in place to ensure payroll costs charged to the grant properly reflected payroll changes and that amounts charged to the grant were properly supported by current wage rates. Identification as a Repeat Finding: Not a repeat finding Recommendation: Southwest Behavioral Health Services, Inc. and Subsidiaries should implement controls to ensure payroll costs charged to the grant properly reflected payroll changes and that amounts charged to the grant were properly supported by current wage rates. Views of Responsible Officials: Management of Southwest Behavioral Health Services concurs with the finding. See Corrective Action Plan.
Finding No. 2022-003 Federal Agency: U.S. Department of Education Assistance Listing No. and Title: 84.027 Special Education – Grants to States (IDEA, Part B) Area: Allowable Costs/Cost Principles Questioned Costs: $0 Criteria: The Schedule of Expenditures of Federal Awards (SEFA) must be supported by underlying accounting and other records used in preparing the financial statements. 2 CFR 200.403(g) provides that costs must be adequately documented to be considered allowable under Federal awards. 2 CFR 200.430(i)(1)(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: 1. For the year ended September 30, 2022, the total amount of payroll expense under ALN 84.027 determined from the journal entry details supporting the SEFA (or general ledger) was lower by $480,743 as compared to the total amount of payroll expense per labor cost summary (or subsidiary ledger). It was further noted that $404,198 out of this amount pertains to costs initially charged under the program but were reclassified to the Education Stabilization Fund (ESF) federal program through a general ledger entry only. No questioned costs are raised as the payroll costs that caused the variance were identified in detail. 2. For 3 (or 8%) of 40 transactions tested aggregating $61,202 out of $3,196,892 in total payroll expenditures, employee timecards were not provided. No questioned costs are raised as summary timesheets were provided. See Schedule of Findings and Questioned Costs for chart/table. Cause: PSS did not perform a reconciliation of the general ledger and subsidiary ledger for payroll costs. In addition, PSS failed to ensure that costs charged to the grant are adequately supported. Effect: PSS is in noncompliance with applicable allowable costs/cost principles requirements. Recommendation: PSS should implement a regular reconciliation of its labor cost summary report with the general ledger journal entries and ensure that any discrepancies are resolved or validly supported. Further, PSS should strengthen recordkeeping procedures so that documents are readily available to substantiate costs charged to the grant. Views of responsible officials: The PSS Corrective Action Plan provides a detailed rationale for disagreement with the finding. Auditor response: Condition 1 – The finding does acknowledge that PSS reclassified the amount under ESF funds. Given the knowledge of the journal entry limitation, PSS failed to show evidence of effort to regularly reconcile the labor cost summary report with the general ledger. The condition remains. Condition 2 – Based on our understanding of PSS’ internal controls, timecards are required to be provided every pay period to support the payment of salaries and wages. The condition remains.
Finding No. 2022-003 Federal Agency: U.S. Department of Education Assistance Listing No. and Title: 84.027 Special Education – Grants to States (IDEA, Part B) Area: Allowable Costs/Cost Principles Questioned Costs: $0 Criteria: The Schedule of Expenditures of Federal Awards (SEFA) must be supported by underlying accounting and other records used in preparing the financial statements. 2 CFR 200.403(g) provides that costs must be adequately documented to be considered allowable under Federal awards. 2 CFR 200.430(i)(1)(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: 1. For the year ended September 30, 2022, the total amount of payroll expense under ALN 84.027 determined from the journal entry details supporting the SEFA (or general ledger) was lower by $480,743 as compared to the total amount of payroll expense per labor cost summary (or subsidiary ledger). It was further noted that $404,198 out of this amount pertains to costs initially charged under the program but were reclassified to the Education Stabilization Fund (ESF) federal program through a general ledger entry only. No questioned costs are raised as the payroll costs that caused the variance were identified in detail. 2. For 3 (or 8%) of 40 transactions tested aggregating $61,202 out of $3,196,892 in total payroll expenditures, employee timecards were not provided. No questioned costs are raised as summary timesheets were provided. See Schedule of Findings and Questioned Costs for chart/table. Cause: PSS did not perform a reconciliation of the general ledger and subsidiary ledger for payroll costs. In addition, PSS failed to ensure that costs charged to the grant are adequately supported. Effect: PSS is in noncompliance with applicable allowable costs/cost principles requirements. Recommendation: PSS should implement a regular reconciliation of its labor cost summary report with the general ledger journal entries and ensure that any discrepancies are resolved or validly supported. Further, PSS should strengthen recordkeeping procedures so that documents are readily available to substantiate costs charged to the grant. Views of responsible officials: The PSS Corrective Action Plan provides a detailed rationale for disagreement with the finding. Auditor response: Condition 1 – The finding does acknowledge that PSS reclassified the amount under ESF funds. Given the knowledge of the journal entry limitation, PSS failed to show evidence of effort to regularly reconcile the labor cost summary report with the general ledger. The condition remains. Condition 2 – Based on our understanding of PSS’ internal controls, timecards are required to be provided every pay period to support the payment of salaries and wages. The condition remains.
Finding 2022-004 – Allowable costs – payroll Assistance Listing #: 93.243 Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. Condition: During fiscal year 2022, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and management was unaware that using budget estimates was not allowed without further reconciliation against actual time or effort activities. Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis. Response: The Organization is now aware that utilization of budget estimates is not allowed for charging payroll and will utilize proper accounting treatment going forward.
Finding 2022-004 – Allowable costs – payroll Assistance Listing #: 93.243 Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. Condition: During fiscal year 2022, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and management was unaware that using budget estimates was not allowed without further reconciliation against actual time or effort activities. Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis. Response: The Organization is now aware that utilization of budget estimates is not allowed for charging payroll and will utilize proper accounting treatment going forward.
Finding 2022-004 – Allowable costs – payroll Assistance Listing #: 93.243 Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. Condition: During fiscal year 2022, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and management was unaware that using budget estimates was not allowed without further reconciliation against actual time or effort activities. Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis. Response: The Organization is now aware that utilization of budget estimates is not allowed for charging payroll and will utilize proper accounting treatment going forward.
Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes 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: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.
Federal Agency: U.S. Department of Health and Human Services Program: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Major Program Compliance Requirement: Allowable Costs/Activities Allowed Criteria: In accordance with 200.430(i) in Subpart E of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), changes 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: Accurate and reliable records are necessary to meet ongoing financial reporting and operations needs and requirements. During our testing of the Organization’s compliance with Assistance Listing 93.592 Family Violence Prevention and Services/Discretionary, the Organization was unable to provide documentation that compensation rates were approved by management or the Board of Directors for all employees (5) selected for testing. Cause: The Organization did not consistently document in personnel records or elsewhere employee compensation or changes to employee compensation rates that were approved by management or the Board of Directors. Effect: The absence of approved employee compensation inhibits the Organization from complying with federal program requirements and the potential of disallowed costs and/or repayment to the federal agency. Recommendation: The Organization should retain all supporting documentation for reported expenditures.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-004—Allowable Costs/Cost Principles Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support payroll disbursements were not maintained for federal award programs. We specifically noted the following: • There is no documentation of an employee’s approved pay rate. • The Institute has not developed formal accounting or personnel policies and procedures that meet the requirements of federal statutes. Questioned Costs: Undeterminable Context: Six of six payroll disbursements tested were not adequately documented. Cause: The Institute was not aware of the Uniform Guidance requirements regarding allowable costs/cost principles (2 CFR Part 200.403), and compensation for personal services (2 CFR Part 200.430). Additionally, the Institute has not developed formal accounting or personnel policies. Effect: The Institute may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendations: The Institute should develop formal accounting and personnel policies and procedures that meet the requirements of the Uniform Guidance. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
2022-002—Unallowable Gift Card Disbursements Charged to Federal Program Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.231 – COVID-19: Epidemiology and Laboratory Capacity Award #: Various Award Period: 09/30/2021 – 09/29/2026 Estimated Questioned Costs: $15,300 Compliance Requirement: Allowable Costs/Cost Principles Statement of Condition AAIHB distributed gift cards to both salaried employees and independent contractors as a gesture of appreciation for working extended hours related to COVID-19 contact tracing efforts. The total value of the gift cards was approximately $15,300 and was charged to the COVID-19: Epidemiology and Laboratory Capacity grant (AL #93.231). For contractors, these gift cards were provided in addition to their regular compensation. The gift card disbursements were not processed through payroll nor formalized in contract terms, and there is no documentation indicating the entity obtained approval from the awarding agency. Criteria In accordance with 2 CFR § 200.403, costs charged to federal awards must be necessary, reasonable, allocable, and conform to limitations set forth in federal regulations. Per 2 CFR § 200.421(e)(3), the cost of gifts—including cash or cash equivalents such as gift cards—is generally unallowable. Compensation for employees must comply with 2 CFR § 200.430, including support through written policies and documentation of time and effort. Contractor payments must align with procurement standards in 2 CFR § 200.318–200.324 and be governed by written contracts. Effect The use of federal funds to provide gift cards constitutes an unallowable cost under Uniform Guidance. The questioned amount may be subject to repayment to the awarding agency or passthrough entity. Cause The auditee sought to recognize the extraordinary efforts of personnel during the COVID-19 public health response. However, they were unaware that the use of gift cards for this purpose was inconsistent with Uniform Guidance and lacked prior approval or supporting policy. Recommendation We recommend the auditee discontinue the use of federal funds for gift card distributions. All compensation for employees should be processed through payroll, supported by appropriate documentation and internal policies. Payments to contractors should be governed by written contracts and comply with applicable procurement standards. If the auditee believes these costs are justifiable, they should consult the awarding agency for a determination and, if necessary, reimburse the federal award.
Finding Number: 2022-023 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.555, 10.559, 10.582 Award #: 4V1300308 Award Period: 10/01/2021 – 9/30/2022 Government Department/Agency: Department of Education (VIDE) Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (1.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principal process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records. • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100%); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – During our testing of allowable costs for payroll expenditures incurred throughout the year, we sampled and selected 11 of 104 payroll disbursements and noted the following: • 11 instances where the approved timesheet for the pay period selected was not available for review. • 11 instances where VIDE did not provide support that time and effort is charged in accordance with A-87 requirements. • 4 instances where the NOPA provided did not include any evidence that the employee was approved to be federally reimbursed for the project code utilized in the payroll register. • One instance where the project code on the approved NOPA did not agree with the project code utilized on the payroll register. • 7 instances where the payroll register did not include and employee’s retirement and health insurance benefits for the pay period selected. • One instance where the employee’s pay rate in the approved NOPA provided did not agree with the pay rate in the payroll register. • One instance where the payroll register did not show any hours worked by the employee for the pay period selected. Questioned Costs – None. Context – This is a condition identified per review of VIDE’s compliance with the specified requirements using a statistically valid sample. The total payroll expenditures charged to the program in fiscal year 2022 were $205,418. The amount sampled is $22,738 The known amount of the instances of inconsistent funding allocation is $22,738. Effect – An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Cause – VIDE does not appear to have adequate policies and procedures to ensure compliance with applicable cost principles and ensure that an appropriate level of review and approval was completed prior to charging costs to a federal program. Recommendation – We recommend that VIDE reevaluate and improve internal controls to ensure adherence to federal regulations related to the fiscal administrative requirement for expending and accounting for payroll and to ensure proper and accurate funding allocation of payroll cost. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-020 Prior Year Finding Number: 2021-019 Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: 4VI400408 Award Year: 10/01/20 – 09/30/21 10/01/21 – 09/30/22 Government Department/Agency: Department of Human Services (DHS) Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (1.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principal process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records. • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100%); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – During our testing of allowable costs for payroll expenditures incurred throughout the year, we sampled and selected 60 of 1,854 payroll disbursements and noted the following: • 13 instances where DHS did not consistently apply funding allocation in accordance with the Notice of Personnel Action (NOPA). Of the 13, we found 5 instances where hours that should have been charged 100% to federal funds were split 50/50 (local/federal) and 8 instances in which hours that should have been split 50/50 were charged 100% (3), 95% (3), 75% (1), and 55% (1) to federal funds. • One instance where an employee’s compensation was charged to SNAP while working on a different federal program. • One instance in which overtime hours noted per the employees’ timesheet did not agree to the overtime hours in the payroll register. Further, we noted that internal controls identified did not appear to be operating at a level of precision to ensure compliance with the above-mentioned requirements. Questioned Costs – Not Determinable. Context – This is a condition identified per review of DHS’ compliance with the specified requirements using a statistically valid sample. The total payroll expenditures charged to the program in fiscal year 2022 were $3,354,155. The amount sampled is $132,885. The known amount of the instances of inconsistent funding allocation is $6,453. Effect – An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Cause – DHS does not appear to have adequate policies and procedures to ensure compliance with applicable cost principles and ensure that an appropriate level of review and approval was completed prior to charging costs to a federal program. Recommendation – We recommend that DHS reevaluate and improve internal controls to ensure adherence to federal regulations related to the fiscal administrative requirement for expending and accounting for payroll and to ensure proper and accurate funding allocation of payroll cost. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-052 Prior Year Finding Number: 2021-046 Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Education COVID-19 - Education Stabilization Fund State Educational Agency (Outlying Areas) (ESF-SEA) ALN: 84.425A Award #: S425A200004, S425A210004 Award Period: 06/22/2020 - 09/30/2022 01/13/2021 - 09/30/2023 COVID-19 - Education Stabilization Fund Governors (Outlying Areas) (ESF-Governor) ALN: 84.425H Award #: S425H200003, S425H210003 Award Period: 06/29/2020 - 09/30/2022 01/13/2021 - 09/30/2023 COVID-19 – American Rescue Plan - Outlying Areas State Educational Agency (ARP-OA SEA) ALN: 84.425X Award #: S425X210004 Award Period: 04/08/2021 – 09/30/2024 Government Department/Agency: Department of Education (VIDE) Office of Management and Budget (OMB) Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records: • Reasonable reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – For ALN 84.425A, we sampled and selected 60 out of 2,319 payroll expenditures and noted 4 timesheets were not available for review. Further, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. Questioned Costs – Not determinable. Context – This is a condition identified per review of VIDE’s compliance with the specified requirements using a statistically valid sample. The total payroll expenditures charged to program in fiscal year 2022 is $3,138,454. Total amount sampled is $98,332. The known amount of the exceptions if $7,968. Effect – Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – VIDE does not appear to have adequate policies and procedures in place to ensure compliance with applicable cost principles and maintenance of underlying documentation. Recommendation – We recommend that VIDE improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. Where employees work on multiple activities or cost objectives, a distribution of salaries or wages should be supported by personnel activity reports (time and attendance) or equivalent documents. Such information should also be monitored, retained, and approved by a responsible official of VIDE in a timely manner. Views of Responsible Officials - The Government concurs with the auditor’s findings and recommendations. VIDE is addressing audit findings related to payroll activities by enhancing internal controls to ensure compliance with federal regulations. Key measures include improving timesheet management through electronic submission, mandatory supervisor review, and secure storage. Additionally, VIDE will strengthen rate verification processes with a standardized checklist for comparing NOPA rates with payroll system rates, requiring payroll staff to complete it at each pay cycle and maintain a discrepancy tracker. Mandatory training sessions will be conducted for employees and supervisors to ensure understanding of the new policies, covering timesheet completion, rate verification, and adherence to guidelines. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-056 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Disease ALN: 93.323 Award #: NU50CK000507 Award Year: 08/01/19 – 07/31/24 Government Department/Agency: Department of Health (DOH) Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Control Section (a), requires the non-federal entities receiving Federal awards (1.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100%); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – DOH was unable to reconcile the payroll expense include in the SEFA ($2,025,690) with the payroll expense in the payroll register ($1,909,128). As a result, the auditor was not able to establish the completeness of the population and was unable to perform testing procedures. Questioned Costs – None. Context – This is a condition identified per review of DOH’s compliance with the specified requirements. Cause – DOH does not appear to have adequate policies and procedures in place to review and reconcile program expenditures. Effect – Lack of proper reconciling information can result in noncompliance with laws and regulation along with loss of funding. Recommendation – We recommend that DOH improve internal controls to ensure program data is reconciled, monitored and retained in order to facilitate adherence to federal regulations and compliance requirements. Views of Responsible Official - The Government concurs with the auditor’s findings and recommendations. DOH acknowledges the auditor's finding regarding the inability to reconcile payroll expenses in the SEFA with the payroll register due to untimely payroll adjustments. To address this, DOH is training its team and ensuring staff have access to make necessary adjustments in the Government Financial Management System starting FY2024. Moving forward, DOH will enhance its SOPs by holding monthly reconciliation meetings with relevant program teams for timely adjustments and continuous monitoring. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-063 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Payroll Activities Program: U.S. Department of Health and Human Services CCDF Cluster ALN: 93.575, 93.489 Award #: Various Award Period: Various Government Department/Agency: Department of Human Services (DHS) Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (1.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principal process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records. • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100%); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 67 out of 302 payroll transactions and in all instances found that DHS did not consistently apply funding allocation in accordance with the Notice of Personnel Action (NOPA). We found the project code approved on the NOPA did not agree to the project code used on the payroll register. However, in all instances we found the employee’s actual time and effort was appropriately charged to the CCDF program. Thus, internal controls were not operating at a level of precision to ensure compliance with the allowable costs compliance requirement. Questioned Costs – None. Context – This is a condition identified per review of DHS’s compliance with the specified requirements using a statistically valid sample. The total amount of payroll expenditures charged to the program were $820,305. Total amount sampled was $202,805. Effect – Failure to properly update an employee’s NOPA can result time and effort charged to the incorrect project code resulting in noncompliance with laws and regulations along with loss of funding. Cause – DHS does not appear to have adequate policies and procedures in place to ensure compliance with applicable cost principles. Recommendation – We recommend that DHS improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. The Division of Human Resources is updating the Notice of Personnel Actions to include the necessary Project code at the start of each fiscal year. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
ALN: 84.126 Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States Federal Agency: United States Department of Education Pass-Through Entity: Texas Health and Human Services Commission Award Number(s): HHS000186000005, HHS000202900008 Federal Award Year: 2022 Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested did not have review and approval of the Supervisor on the timecard. Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Effect: The Entity may unintentionally under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause: The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Questioned Costs: No questioned costs identified.
ALN: 84.126 Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States Federal Agency: United States Department of Education Pass-Through Entity: Texas Health and Human Services Commission Award Number(s): HHS000186000005, HHS000202900008 Federal Award Year: 2022 Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested did not have review and approval of the Supervisor on the timecard. Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Effect: The Entity may unintentionally under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause: The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Questioned Costs: No questioned costs identified.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
2022-018 Activities Allowed or Unallowed, Allowable Costs/ Cost Principles - Payroll Federal Agency: Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund (DWSRF) Cluster ALN: 66.468, 66.483 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 582-22-30745 9/1/2021 ? 8/31/2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.430 (i-vii), the Texas Commission on Environmental Quality must ensure that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) comply with the established accounting policies and practices of the non-Federal entity; and (vii) support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing, we selected 40 payroll-related expenditures incurred during the fiscal year totaling $134,012 to validate allowability and proper documentation of time and effort. We noted that for three out of the 40 samples, wages charged to the federal program were overstated by $27. Questioned costs: $27 Context: See ?Condition.? Cause: Hours incorrectly charged to the grant are a result of system and manual errors when allocating time to federal grants. Effect: Unallowable costs charged to the grant will result in noncompliance with the grant terms and questioned costs. Repeat Finding: No Recommendation: TCEQ should strengthen its controls related to review of payroll expenditures for compliance with federal time and effort requirements to ensure unallowed costs are not charged to the grant. Views of responsible officials: Federally funded and site-specific employees are required to record their time accurately and to charge to grants correctly. Supervisors are required to implement the quality control measures necessary to ensure that salaries and wages are based on records that accurately reflect the work performed.
ALN: 84.126 Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States Federal Agency: United States Department of Education Pass-Through Entity: Texas Health and Human Services Commission Award Number(s): HHS000186000005, HHS000202900008 Federal Award Year: 2022 Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested did not have review and approval of the Supervisor on the timecard. Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Effect: The Entity may unintentionally under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause: The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Questioned Costs: No questioned costs identified.
ALN: 84.126 Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States Federal Agency: United States Department of Education Pass-Through Entity: Texas Health and Human Services Commission Award Number(s): HHS000186000005, HHS000202900008 Federal Award Year: 2022 Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested did not have review and approval of the Supervisor on the timecard. Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Effect: The Entity may unintentionally under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause: The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Questioned Costs: No questioned costs identified.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
Significant Deficiency CFDA No.: 16.575 Program Title: Crime Victim Assistance Federal Award No.: 2020-V2-GX-004 and 2019-V2-GX-0011 Federal Award Year: September 30, 2021 Name of Pass-through Entity: Texas Office of the Governor ? Criminal Justice Division (CJD) and Children?s Advocacy Centers of Texas, Inc. (CACTX) Name of Federal Agency: U.S. Department of Justice 2022-001 Allowable Costs Criteria 2 CFR 200.430(i)(1)(i) states, ?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.? In addition, state and federal grant standards require that the method used to allocate a cost should be reasonable and measurable means of distributing the cost to those funding sources, and consistently applied for the type of cost. Condition During the audit, we noted two instances in which salaries and wages charged to the grant did not agree to time allocated on timesheets. In addition, we noted multiple variances in indirect costs charged to the grant because of misapplication of the Organization?s cost allocation plan. The total extrapolated difference amounted to less than 1% of total expenditures for this grant. Questioned Cost $0 Context This does not appear to be an isolated instance. Cause Coding of timesheets in accounting software was not reviewed prior to preparation of requests for reimbursement. In addition, the Organization did not update and apply its cost allocation plan correctly on a monthly basis. Effect The Organization had multiple variances in salaries and indirect costs. Recurrence This is a repeat finding. Recommendation The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Views of Responsible Officials The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement.
2022-018 Activities Allowed or Unallowed, Allowable Costs/ Cost Principles - Payroll Federal Agency: Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund (DWSRF) Cluster ALN: 66.468, 66.483 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 582-22-30745 9/1/2021 ? 8/31/2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.430 (i-vii), the Texas Commission on Environmental Quality must ensure that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) comply with the established accounting policies and practices of the non-Federal entity; and (vii) support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing, we selected 40 payroll-related expenditures incurred during the fiscal year totaling $134,012 to validate allowability and proper documentation of time and effort. We noted that for three out of the 40 samples, wages charged to the federal program were overstated by $27. Questioned costs: $27 Context: See ?Condition.? Cause: Hours incorrectly charged to the grant are a result of system and manual errors when allocating time to federal grants. Effect: Unallowable costs charged to the grant will result in noncompliance with the grant terms and questioned costs. Repeat Finding: No Recommendation: TCEQ should strengthen its controls related to review of payroll expenditures for compliance with federal time and effort requirements to ensure unallowed costs are not charged to the grant. Views of responsible officials: Federally funded and site-specific employees are required to record their time accurately and to charge to grants correctly. Supervisors are required to implement the quality control measures necessary to ensure that salaries and wages are based on records that accurately reflect the work performed.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.
Finding 2022-002: Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal program information: U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Health and Human Services, CFDA Number 93.575, CCDF Cluster; U.S. Department of Energy, CFDA Number 81.042, Weatherization Services for Low- Income Persons Criteria: The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition: For the year ended July 31, 2022, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2022, there is no formal documentation of this review process. Questioned Costs: Not determinable. Context: For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2022. We tested 40 individual charges of salaries and wages for each of the major federal award programs. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect: WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause: Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation: Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views of responsible officials and planned corrective actions: For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until FY23 because the auditor’s field work for fiscal year 2021 ended after the close of fiscal year 2022.