Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Federal Award Identification Number: 43CAZ03215 Award Period: January 1, 2022 – December 31, 2022 Type of Finding: Material Weakness in internal control over compliance Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part 200.430(i) states “Cost must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition: Employee change of status forms are not consistently maintained in accordance with applicable requirements. Questioned Costs: None. Context: 5 Employee files that were selected for verification disclosed 4 instances where forms were not available for review. Cause: Employee change of status forms or offer letters were not maintained on file or available for review. Effect: Inability to review employee change of status forms or offer letters limits the ability to verify costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain compliance with allowable costs as required by 2 CFR 200.430. Repeat Finding: Yes Recommendation: Offer letters or employee change of status forms should be maintained on file. We recommend management implement a second layer of review of personnel files. Views of Responsible Official: Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured. This includes hiring documentation and change of status forms for employees.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Federal Award Identification Number: 43CAZ03215 Award Period: January 1, 2022 – December 31, 2022 Type of Finding: Material Weakness in internal control over compliance Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part 200.430(i) states “Cost must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition: Employee change of status forms are not consistently maintained in accordance with applicable requirements. Questioned Costs: None. Context: 5 Employee files that were selected for verification disclosed 4 instances where forms were not available for review. Cause: Employee change of status forms or offer letters were not maintained on file or available for review. Effect: Inability to review employee change of status forms or offer letters limits the ability to verify costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain compliance with allowable costs as required by 2 CFR 200.430. Repeat Finding: Yes Recommendation: Offer letters or employee change of status forms should be maintained on file. We recommend management implement a second layer of review of personnel files. Views of Responsible Official: Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured. This includes hiring documentation and change of status forms for employees.
2022-007 Payroll (Material Weakness) Criteria: Title 2 CFR Part 200 §200.430(g). Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Timesheets were not always obtained and did not include information to support employee time and effort as required by federal regulations. Time records did not always include evidence of review/approval. Additionally, for two employees of 60 tested, differences existed between the approved hourly pay rate and the hourly rate paid per the payroll summary. Cause: As discussed at Finding 2022-005, we noted that no policy exists over the form and content of documentation to support employee time and effort under 2 CFR Part 200. And policies are not in place for the review and approval of payroll transactions. Effect: Payroll records did not comply with federal regulations. Because of the failure to require appropriate documentation and review/approval, there is increased risk that payroll transactions could be inappropriately charged to government programs. Questioned Costs: Not determinable due to limitations in the Organization’s accounting system. Perspective: When timesheets were not obtained, we were able to examine other evidence of time worked (such as emails). Forty of 60 tested had no evidence of approval. Repeat Finding: Yes Recommendation: Procedures should be implemented to require appropriate contemporaneous documentation to support time and effort reporting under 2 CFR Part 200. In addition, procedures should also be implemented to require the review and approval of payroll. Views of Responsible Officials: Management acknowledges the control weaknesses as described above as there was not proper documentation of payroll transactions including evidence of review and approval. The Organization has undertaken a review of its policies and procedures, including consultation of an outside accounting firm to ensure proper control procedures over payroll are implemented.
According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Finding 2022-002: Lack of documentation of review and approval - Material Weakness Program name: Office for Coastal Management Assistance Listing: 11.473 Federal award Identification number: 20 NFWF 339630 Federal award year: 9/1/2020 - 8/31/2023 Federal awarding agency: U.S. Department of Commerce Criteria - In accordance with 2 CFR 200.303, recipients and subrecipients must establish, document and maintain effective internal control over Federal awards. These controls should be in compliance with Federal statutes, regulations, and the terms and conditions of the award, and should align with standards such as the “Standards for Internal Control in the Federal Government” (Green Book) or the COSO framework. This includes controls over: * Payroll: Ensuring labor charges are accurate, allowable, and properly approved (2 CFR 200.430). * Expenses: Ensuring proper documentation and approval. (2 CFR 200.400(d) ) * Reporting: Ensuring financial reports are accurate, complete, and reviewed prior to submission (2 CFR 200.328). Condition - The Organization has limited written processes of certain transaction classes. There was a pervasive lack of documentation of approval over transactions, including payroll, expenses, and reporting. Cause - The Organization did not maintain or consistently apply documentation protocols for internal control reviews. Formal documentation practices were not in place during the audit period. Effect - Lack of documentation as evidence that controls over compliance were being performed. Documentation should be maintained as evidence that sufficient control activities are in place and would effectively prevent or detect and correct noncompliance. Controls must be followed for every transaction and documentation of the control being performed must be maintained. Questioned costs - None identified. Perspective - The deficiency was pervasive across multiple compliance areas and was not isolated to a specific transaction or department. The scope indicates a systemic control weakness during the audit period. Identification of Repeat Findings - This is not a repeat finding. Recommendation - We recommend that the Organization ensure updated policies and procedures are implemented and consistently applied. This includes: * Documented review and approval of all transactions related to payroll, expenses, and reporting. * Maintenance of written evidence supporting such reviews. * Regular training and internal monitoring to ensure control procedures are consistently followed. Management response - See corrective action plan
AL number: 14.231, AL title: Emergency Solutions Grant Program Federal award identification number and year: LAHSA agreements: GT-BH-ABH-021, GT-BH-RTV-001, GT-BH-RTV-002, GT-BH-RTV-003, GT-BH-RTV-004, GT-BH-RTV-009, GT-TLS-N-013, GTRRH- RR-02, GT-CH-WS-001, GT-1878-2102-001 Name of federal agency: U.S. Department of Housing and Urban Development Name of pass-through entity: Los Angeles Homeless Services Authority Repeat finding: No Criteria: wages must be based on records that accurately reflect the work performed. Specifically: - Employees who work 100% on a single federal award must have certifications stating that all time was dedicated to the grant, signed by the employee or a supervisor with firsthand knowledge, prepared at least semi-annually. - Employees whose time is split among multiple activities must maintain time and effort reports reflecting actual hours worked in a manner consistent with 2 CFR §200.430(g)(vi). - All compensation costs charged to federal awards must be supported by appropriate documentation that complies with the federal cost principles. Condition: Employees who charged 100% of their time to the grant lacked required certifications or timecards documenting that their time was spent exclusively on grant-related activities. - In several instances, no timecards were available. - In other cases, available timecards showed no evidence of review or approval. - Timecards did not indicate program activity. - Timecards lacked evidence of supervisor approval. - Employees whose time was allocated to multiple programs had no indication of how their time was allocated on the time card. We did note, however, that most allocated employees were working on multiple contracts within the same Federal program, and that costs were allocated among the programs based on the number of beds in each facility, which appears to be a reasonable methodology. - Salaried employees did not have a method for indicating time worked. Cause: The organization failed to implement adequate internal controls to ensure compliance with federal timekeeping and documentation requirements for personnel expenses. Additionally, there appears to be a lack of understanding of the documentation and certification requirements under 2 CFR Part 200, Subpart E. Effect or potential effect: The lack of proper documentation and certification creates a risk that unallowable costs were charged to the grant. Questioned cost: N/A Recommendation: Develop and implement policies and procedures to ensure that timecards and/or certifications are completed and retained for all employees who charge 100% of their time to the grant. Implement a compliant system of time and effort reporting for employees whose time is allocated across multiple activities to align with 2 CFR §200.430(g)(vi). Conduct training for all employees and supervisors on the requirements for documenting and certifying time and effort for federal grants. Perform periodic reviews of timekeeping records and compensation charges to verify compliance with federal requirements. Views of reponsible officials: During this period, Hope The Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We are also partnering with our new 3rd party payroll provider to set up time allocation for salaried employees.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.
Allowable Activities and Costs for Provider Relief Fund Significant Deficiency in Internal Control Over Compliance Federal Assistance Listing Number: 93.498 COVID-19 – Provider Relief Fund (PRF) Criteria: Per 2 CFR 200.430 (i), personnel costs charged to federal grants are required to be supported by documentation including time records. Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition: Our audit procedures over payroll expenses charged to the PRF federal program disclosed timesheets that were not approved by management prior to payment. Cause: The Hospital has a policy requiring supervisory approval of timesheets. The absence of the proper approval for the timesheets tested appears to be a lack of management oversight. Effect: Unauthorized wages can result from undocumented reviews and approvals of timesheets. Questioned Costs: None Perspective: Seven timesheets in a sample of forty timesheets were not approved by management. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Hospital enforce their policy requiring supervisory review and approval for timesheets to ensure time recorded by employees’ is valid and accurate, and that the salaries and wages paid is for work performed. View of Responsible Officials: See management’s response to the finding in the accompanying Corrective Action Plan.
Finding Type: Noncompliance and material weakness in internal control over compliance (activities allowed or unallowed and allowable costs / cost principles). Program: Continuum of Care: Assistance Listing Number 14.267 Criteria: The Uniform Guidance (Title 2 CFR 200.430) requires that allocations for salaries must be based on records that reflect the work performed. Payroll records (timesheets) must be supported by internal controls that create the environment to ensure that payroll items are charged to activities that are accurate, allowable, and properly allocated. Any necessary adjustments to these items should be made so that the final amount charged to the activities is accurate, allowable, and properly allocated. Condition/Finding: Salaries and wages were allocated using percentages to distribute payroll costs allocated to grants. Costs were not consistently allocated to reflect the activity actually performed in five out of the six payroll cycles that we tested. Cause: The Organization did have a system of controls in place for the fiscal year ending September 30, 2022 requiring employees report time spent in specific areas on their timesheets. However, the control was overridden by management and was not applied on a consistent basis. There were payrolls tested where timesheet was not compared to payroll journals provided by the payroll service, the accounting records, or the reimbursement requests for grants. Effect: Payroll costs reflected in the books and records of the Organization did not agree to the payroll journals, timesheets, and reimbursement requests. This required the Organization to use spreadsheets and calculation to support grant funding requests. Some timesheets were found to be inaccurate, resulting in employee personnel costs being reimbursed without proper documentation. Questioned Costs: The total amount of payroll reimbursed without timecards documenting actual labor charges was $21,326 during the year ended September 30, 2022. Recommendation: We recommend that the Organization improve its financial management policies and procedures to ensure that multiple staff members are involved in the process of reviewing and allocating personnel expenses to grants. Policies and procedures over payroll should include employees entering time accurately across areas where they spent time, supervisory review, recalculation and approval of timesheets, review of timesheets and compiled time reporting before it is sent to the payroll provider and review of the reporting provided after the payroll run. Payroll postings input into the accounting system should accurately reflect time spent in each grant area (class) and grant reporting and reimbursement requests should be prepared using those numbers. View of Responsible Officials (Corrective Action): See corrective action plan.
Finding 2022-004 Program Affected Under the U.S. Department of Health and Human Services - Award Year October 1, 2021 - September 30, 2022: Assistance Listing 93.262 Occupational Safety and Health Program Criteria 2 CFR §200.430(i) specifies that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated..." Condition and Context During our program audit procedures related to the payroll cycle, we noted an internal control deficiency related to allocation of payroll costs among federally funded programs. Management did not perform sufficient review of payroll allocations to identify that some payroll expenses were being recorded in excess of readily available wage and time and effort data. We tested a nonstatistical sample of 13, totaling $100,952 from a population totaling $672,541. Cause and Effect The condition identified was caused by infrequent and periodic review of program-related payroll costs which were reconciled on a biannual basis. This process did not occur on a pay period basis. This resulted in an overstatement of program-related payroll expenses of $6,348. Questioned Costs $6,348 Identification as a Repeat Finding, if Applicable Not applicable. Recommendation We recommend the Organization strengthen controls surrounding program-related record keeping, including increasing the frequency of reconciliations and program wage allocation procedures to match the payroll cycle. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Education Stabilization Fund, the following problems were noted: • Timesheet or payroll service reports for twelve of the fourteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that five of the fourteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for any of the fourteen employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Education Stabilization Fund.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(i) outlines the standards for appropriate documentation of personnel expenses. The current standards require that charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurance the charges are accurate, allowable and properly allocated. In addition, semiannual certifications of time and effort spent working on federal programs are required for employees working on a single cost objective or employees whose salary is supported by only one federal program to document the personnel expenses. During the testing of time and attendance records of employees paid from the Title I Grants to Local Educational Agencies, the following problems were noted: • Timesheet or payroll service reports for twelve of the sixteen employees tested were not approved by the appropriate Principal, Director or Supervisor, as applicable. • Documentation was not provided to support that seven of the sixteen employees tested were paid in accordance with the approved salary or stipend schedules. • Time and effort reports were not provided for one of twelve employees tested to document personnel charges to the federal programs. The Dallas County Board of Education (the “Board”) did not have internal controls in place to ensure all timesheets were properly approved, employees were paid in accordance with approved salary schedules and semiannual certifications of time and effort spent working on the federal programs were properly completed. As a result, the Board is not in compliance with the Uniform Guidance documentation requirements for personnel services charged to the Title I Grants to Local Educational Agencies Program.
Criteria: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i)Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii)Be incorporated into the official records of the non-Federal entity; (iii)Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv)Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis; (v)Comply with the established accounting policies and practices of the non-Federal entity; (vi)Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Citation: 2 CFR 200.430(i) Condition: Electronic timesheets are maintained for all employees to document time spent on this grant as required by the funder; however, there was no evidence of supervisory review available within the timekeeping system for the period covering October 2021 through May 2022. For the period after May 2022 through August 31, 2022, the review was inconsistently documented. Cause: There was no evidence of the supervisory review to ensure salary expense was distributed to specific Federal awards for the period from October 2021 to May 2022. Effect: There is a risk that the salary of an employee could be distributed to a federal award at an amount that is different than the actual time spent on that Federal program. Context: We reviewed timesheets and noted the entity?s system of internal control was not designed to include a supervisors? review of the accuracy of timesheets to verify that an employees? time was distributed to the program that they spent time on from October 2021 to May 2022. Repeat Finding: Yes Recommendation: We recommend that all timesheets and other electronic records used to track time spent on the program be reviewed by a supervisor and that this review be documented.
Reference Number: 2022-001 Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Commission did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses applied to the federal program. Context: Forty payroll transactions were selected for testing and one of the transactions charged to the grant was not supported by a timesheet. The timesheet was also not approved by a supervisory or independent individual. Questioned costs: The amount charged to the grant for this transaction was $582. Cause: Controls were not operating effectively to ensure that payroll reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. Views of responsible officials: One of our employee?s timesheets was supposed to charge Account #500, but the incorrect formula was used and summed to Account #802 in December. This resulted in $582 difference between the two projects identified as a questioned cost above. By the end of 2022 fiscal year, however, we didn't overcharge project #802. ICPRB expended nearly $80,000 more on this project than was charged to the federal government so this oversight had no effect. This minor error resulted from the termination of our former Admin Director and the resignation of his temporary replacement. Our new Office Manager (hired on February 15, 2023) has assumed the responsibility of reviewing the timesheets so this will not be repeated. In addition, we have decided to block employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software.
Item 2022-001 Written policies, procedures, and standards of conduct Water and Waste Disposal Systems for Rural Communities Assistance Listing Number 10.760 U.S. Department of Agriculture Grant period: Year ended September 30, 2022 Questioned Costs ? $0 Condition ? The Board does not have all of the written policies, procedures and standards of conduct required by UG. Criteria ? Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits Cause of Condition ? The Board has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition ? Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation ? We recommend that the Board implement the required written policies and procedures. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.
2022-001: Controls over the payroll process should be enhanced. Type: Significant deficiency in internal control over compliance Assistance Listing Number, Federal Agency, Program Name, Program Title, Pass-through Grantor, and Pass-through Name and Grant Number: Assistance Listing #93.044, U.S. Department of Health and Human Services, Passed Through Area Agency on Aging, Special Programs for the Aging-Grants for Supportive Services and Senior Centers, Title III, Part B - Chore, 20-9046-C Criteria: Per 2CFR 200.430, personnel expenses that are charged to a federal program must, among other things, be based on records that accurately reflect the work performed. Condition: During our testing of payroll charged to the program, we noted differences between the personal activity reports and the amount charged to the program. Cause: The Council?s calculation of the allocation of wages to the program did not include essential pay or opt-out compensation as part of the hours worked. Context: Four (4) out of seven (7) personal activity reports tested for the Chore program differed from the amount charged to the program. Effect: No financial effect since the Council charges less than 100% of the eligible salaries, wages, and payroll taxes to the Chore program. Recommendation: The control process should be reviewed and modified appropriately so that control would be established to note any differences between the amounts being charged and personal activity reports.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.
Finding number: 2022-001 AL number: 14.231 AL title: Emergency Solutions Grants Program Federal award identification number and year: 32101372, 32101373, 32101371, 32101283, 32101297; 2022 Name of Federal agency: Department of Housing and Development Urban Name of pass-through entity: County of Marin Repeat finding: No Criteria: Per 2 CFR 200.430, "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed", and records must be "supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated". Furthermore, "budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards", and there must be an after-the-fact review to ensure payroll costs are accurately allocated. Condition: During our testing of payroll costs charged to the Federal award, we noted that from the start of the award period through June 2022 the Society allocated and charged payroll costs to the Federal award based on budget estimates and an after-the-fact review was not performed. This resulted in the Federal award not being charged for the actual costs incurred for the award. Management performed an analysis of the time incurred and charged to the Federal award and determined that the Society overbilled the Federal award $68,357 and $47,532 during the years ended September 30, 2022 and 2021, respectively. Management revised the process for allocating payroll costs in July 2022 to a methodology that reflects the actual time incurred. Cause: The Society previously had not administered Federal awards subject to the Uniform Guidance and therefore did not have a system of internal control in place that complies with the standards for documentation of personnel expenses required by the Uniform Guidance. Possible effect: The Society overbilled the Federal award by $115,889 over a two year period. Questioned cost: Management performed an analysis of the time incurred and charged to the Federal award and determined that the Society overbilled the Federal award $68,357 and $47,532 during the years ended September 30, 2022 and 2021, respectively. Recommendation: We recommend that the Society continue to follow the internal controls and procedures around payroll allocation that were implemented in July 2022. Management should continue to ensure that all payroll costs are allocated to Federal awards based on the actual time spent by each employee. Views of responsible officials: Management concurs with the finding and will continue to follow the revised methodology that was implemented in July 2022 for allocating payroll costs to Federal awards such that payroll costs charged to Federal awards
Criteria: The Code of Federal Regulations (CFR) Subpart E ? Cost Principles, ?200.430(i), allowable costs must be adequately documented. ?200.430(i)(1) states ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?? Further, according to 29CFR ?516.5(b) records such as employment contracts or agreements must be retained by employers for at least three years from their last effective date. Condition: For 3 of 115 items tested, or 3% of the sample, we noted that the contract form was signed after the effective date of the renewal of employment. Cause: NMC staff who are responsible for monitoring contract form renewals did not review these personnel files in a timely manner. Effect: NMC did not comply with federal regulations requirements in which contract forms should be signed prior to renewal of employment. With this situation, the employee is working without properly documented approval from authorized personnel. Recommendation: NMC should ensure that human resources personnel adhere to the internal control policies and procedures relevant to renewal of employment. Ample time to process employment documents should be available to ensure that the required approvals are obtained prior to renewal of employment. Views of Responsible Officials See corrective action plan immediately following this schedule of findings and questioned costs.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
Finding 2022-002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Federal Agency: Department of Housing and Urban Development Assistance Listing Number and Title: 14.231 - Emergency Solutions Grant Program Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and ? 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. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the award recipient?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates, and that all necessary adjustments be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time spent was used as a basis for allocating personnel charges to the grant. Questioned Costs: $166,148 (total employee salaries and wages charged to the program) Context: For our direct labor allowable costs sample, Army management indicated that all 10 expenditure selections totaling $12,871 were allocated to the program based on budgeted percentages. There was no evidence that a subsequent review of budget estimates was performed for all the selections. Cause: Current policies and procedures do not require documented timekeeping by employees working on the grant program, which is appropriately reviewed, approved and used as a basis for charges to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Repeat Finding: No. Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping, as well as the salary and wage allocations to the grant, are appropriately documented and accurately reflect the work performed. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.
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. View of Responsible Officials: As part of the ongoing review of procedures, all wage changes must now be approved in writing by the CEO or her designee for all subordinate staff, and by the Board of Directors for the CEO. All wage changes will be submitted to the payroll processor before any adjustments can be made in the system. Additionally, each payroll is reviewed by a second person to ensure compliance. All supporting documentation of compensation changes will also be placed in the employee's personnel file. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.
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. View of Responsible Officials: As part of the ongoing review of procedures, all wage changes must now be approved in writing by the CEO or her designee for all subordinate staff, and by the Board of Directors for the CEO. All wage changes will be submitted to the payroll processor before any adjustments can be made in the system. Additionally, each payroll is reviewed by a second person to ensure compliance. All supporting documentation of compensation changes will also be placed in the employee's personnel file. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.
Finding Number: 2022-009 Prior Year Finding Number: 2021-011 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Immunization Cooperative Agreements ALN: 93.268 Award #: 1 NH23IP922596-02-02 to NH23IP922596-02-11 Award Year: 08/01/2019 ? 06/30/2024 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the Immunization Cooperative Agreements (ICA) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 11 out of 60 sampled payroll items tested for the ICA grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the ICA program in fiscal year 2022 were $2,646,210. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the ICA grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the ICA program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.