FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: $23,398 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Title I Grants to Local Educational Agencies program. Background: The Title I Grants to Local Educational Agencies (Title I) program was authorized under the Elementary and Secondary Education Act of 1965 to help local educational agencies (LEAs) improve teaching and learning in high-poverty schools in particular for children failing or most at-risk of failing, to meet challenging State academic standards. LEAs may operate targeted assistance programs in which children who are failing or most at-risk of failing may be served or schoolwide programs in which all children in eligible schools may be served. Title I funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. Title I funds totaling $377,570 were expended and reported on the Talbot County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “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, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) 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…” Condition: Three individually significant non-personal services expenditures were selected for testing to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. For one individually significant expenditure in the amount of $19,848, adequate supporting documentation in the form of an invoice was not maintained. Additionally, a sample of two employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. It was noted that timesheets were not maintained to evidence accuracy of amounts paid for $3,550 of additional pay. Questioned Costs: Upon testing individually significant expenditures, known questioned costs of $19,848 were identified for expenditures that were not supported by adequate documentation. These known questioned costs related to expenditures that were not tested as part of a sample and should not be projected to a population to determine likely questioned costs. Additionally, upon testing a sample of $99,999 in personal services expenditures, known questioned costs of $3,550 were identified for expenditures not supported by adequate documentation. Using the total personal services expenditures population of $200,603 (excluding benefits payments), we project the likely questioned costs to be approximately $7,121. Therefore, the known and likely questioned costs identified for all unallowable payments throughout the sample and individually significant items tested totaled $23,398 and $26,969, respectively. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the Title I program. Failure to ensure that documentation exists to support the allowability of payments from the Title I fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should review current internal control procedures related to Title I program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District’s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $611,712 were expended and reported on the Talbot County School District’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “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, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) 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 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Condition: A sample of seven non-personal services expenditures was randomly selected for testing using a non-statistical sampling approach. In addition, three individually significant items were selected for testing. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • A purchase order was not maintained for two of the expenditures. • The check amount, invoice, and purchase requisition form for one expenditure did not agree. • One expenditure was not appropriately approved by GaDOE through the Consolidated Application process. In addition, a sample of 15 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • Timesheets or other supporting documentation could not be provided for payments made to 14 employees. • Timesheets provided for six employees did not agree to amounts paid for the corresponding time period. Furthermore, upon completing testing over personal services expenditures for the Title I Grants to Local Educational Agencies (Title I) program, auditor noted that two employees were paid $2,870 from the ESSER fund that could not be supported by timesheets or other documentation. Questioned Costs: Upon testing a sample of $23,522 in non-personal service expenditures, known questioned costs of $9,424 were identified for expenditures not supported by adequate documentation or not properly approved through the Consolidated Application process. Using the total non-personal services expenditures population of $55,926, we project the likely questioned costs to be approximately $22,407. Additionally, upon testing a sample of $118,771 in personal services expenditures, known questioned costs of $46,121 were identified. Using the total personal services expenditure population of $298,264, we project the likely questioned costs to be approximately $115,821. Furthermore, known questioned costs of $2,870 were identified for unsupported ESSER payments upon completing personal services testing associated with the Title I program. Therefore, the known and likely questioned costs identified for unallowable payments totaled $58,415 and $138,228. The following Assistance Listing Number was affected by known and likely questioned costs: 84.425D. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the ESSER program. Failure to ensure that documentation exists to support the allowability of payments from the ESSER fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District’s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $611,712 were expended and reported on the Talbot County School District’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “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, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) 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 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Condition: A sample of seven non-personal services expenditures was randomly selected for testing using a non-statistical sampling approach. In addition, three individually significant items were selected for testing. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • A purchase order was not maintained for two of the expenditures. • The check amount, invoice, and purchase requisition form for one expenditure did not agree. • One expenditure was not appropriately approved by GaDOE through the Consolidated Application process. In addition, a sample of 15 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • Timesheets or other supporting documentation could not be provided for payments made to 14 employees. • Timesheets provided for six employees did not agree to amounts paid for the corresponding time period. Furthermore, upon completing testing over personal services expenditures for the Title I Grants to Local Educational Agencies (Title I) program, auditor noted that two employees were paid $2,870 from the ESSER fund that could not be supported by timesheets or other documentation. Questioned Costs: Upon testing a sample of $23,522 in non-personal service expenditures, known questioned costs of $9,424 were identified for expenditures not supported by adequate documentation or not properly approved through the Consolidated Application process. Using the total non-personal services expenditures population of $55,926, we project the likely questioned costs to be approximately $22,407. Additionally, upon testing a sample of $118,771 in personal services expenditures, known questioned costs of $46,121 were identified. Using the total personal services expenditure population of $298,264, we project the likely questioned costs to be approximately $115,821. Furthermore, known questioned costs of $2,870 were identified for unsupported ESSER payments upon completing personal services testing associated with the Title I program. Therefore, the known and likely questioned costs identified for unallowable payments totaled $58,415 and $138,228. The following Assistance Listing Number was affected by known and likely questioned costs: 84.425D. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the ESSER program. Failure to ensure that documentation exists to support the allowability of payments from the ESSER fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
2022-004 Allocation of Program Effort by Employees – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program: Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 8/31/22) Federal Agency: National Science Foundation Criteria: The financial management requirements include processes and controls over the allocation of personnel time and effort to program activities as required by 2 CFR 200.430. Condition: Our testing of payroll expenses charged to the program noted that the Organization allocates senior personnel time and effort in one year end journal entry as a program expense. Upon review of the supporting documentation for the journal entry, it was noted that one individual included in the allocation was no longer an employee of the Organization during the year ended June 30, 2022. Cause: The Organization lacks written policies, approval procedures and documentation to allocate senior personnel effort and time costs to program accounting records. Effect: The Organization does not maintain a compliant effort system and is not in compliance with 2 CFR 200.430 which could lead to inaccurate allocation of personnel costs to the federal program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2021-005 in the prior year. Recommendation: We recommend the Organization strengthen its controls and processes over time and effort allocations by establishing written policies, timesheet allocations, approvals and segregation of duties in compliance with 2 CFR 200.430. Response: The Organization will improve its procedures for allocating senior personnel time and effort in its accounting and financial record keeping processes. Questioned Costs: $10,000 – Based on the support for the journal entry, this is the amount allocated for the individual that was no longer an employee of the Organization during the year ended June 30, 2022.
Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation for exempt employees' hours was unavailable or incomplete. Cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. Effect or potential effect: During our testing over payroll, we noted $3,875 of exempt employee salary expense that was not supported with accurate time records. This amount projects to a possible total error of $91,107. Questioned cost: $91,107 Recommendation: We recommend that management to regularly review the actual hours that exempt employees worked to determine the amount of time that’s being allocated by the exempt employees represent accurate estimated hours. Views of responsible officials: Behavioral Health Services, Inc. acknowledges the finding identified in the 2022 Single Audit and is committed to addressing the issue to ensure compliance and improve internal controls. The following corrective actions will be implemented: - Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. - Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. Views of responsible officials: - Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. - Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions.
Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation for exempt employees' hours was unavailable or incomplete. Cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. Effect or potential effect: During our testing over payroll, we noted $13,097 of exempt employee salary expense that was not supported with accurate time records. This amount projects to a possible total error of $276,370. Questioned cost: $276,370 Recommendation: We recommend that management to regularly review the actual hours that exempt employees worked to determine the amount of time that’s being allocated by the exempt employees represent accurate estimated hours. Views of responsible officials: Behavioral Health Services, Inc. acknowledges the finding identified in the 2022 Single Audit and is committed to addressing the issue to ensure compliance and improve internal controls. The following corrective actions will be implemented: - Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. - Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. - Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. - Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 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 – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (I) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding l 00% of compensated activities, and ( 4) support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a Federal award and non-Federal award. Condition: During our review of payroll charged to the grant, we noted four employees who did not have documentation to support the distribution of the employee's time spent on grant activities. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee's wages paid using grant funds. Questioned Costs: $271,029 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the distribution of salaries and wages for all employees paid using grant funds. Views of Responsible Officials: Management's views and corrective action plan is included at the end of this report.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
2022-002 Distribution of Compensation – Compliance and Internal Controls over Allowable Costs and Activities and Matching (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Agriculture FALN: 10.561 Federal Award Identification Numbers: 42700-040-0000104184 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2021-2022 Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development FALN: 14.231 Federal Award Identification Numbers: All under this program. See Schedule of Expenditures of Federal Awards. Pass Through Entity: Gwinnett County, Dekalb County, Cobb County, Fulton County Award Year: 2021-2022 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 2 CFR Section 200.430(i) compensation records must support the distribution of the employee’s compensation among specific activities or costs objectives if the employee works on more than one Federal award and compensation of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner. Condition: There are no compensation records to support the distribution of employees’ compensation who work on multiple Federal awards. Effect: The lack of documentation and controls around how employees’ compensation is distributed between multiple Federal awards could result in unallowable costs. Cause: The Association was not aware of the requirements to maintain this documentation. Known Questioned Costs: $11,649 for FALN 14.231 Likely Questioned Costs: $76,266 for FALN 14.231 Perspective: This finding represents a systemic problem as it affects both the allowable activities and costs requirement as well as the matching requirement. Repeat Finding: No Recommendation: We recommend the Association establish policies and procedures to ensure that compensation is properly documented and distributed between Federal awards.
Identification of federal program: U.S. DEPARTMENT OF EDUCATION 84.425D Education Stabilization Fund COVID-19 Elementary and Secondary School Emergency Relief Fund (ESSER I and II) passed through the Indiana Department of Education.Criteria: 2 CFR 200.430(i) requires the auditee to establish and maintain effective internal control over the allocation of personnel expenses whereby charges to Federal awards for personnel-related expenditures are supported by official records of 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 alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: The non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable and properly allocated.Condition: Personnel costs allocated to the award did not agree to time and effort reports maintained for those employees charged to the award.Cause: PPHS does not have a process whereby time and effort reports are reconciled to payroll allocated to federal awards.Effect: Time and effort reports documented that 100% of employee time should have been allocated to the award. However, some employees wages were only partially allocated to the award.Questioned costs: NoneContext: Six (6) out of seven (7) employees tested had time and effort reports noting that 100% of their time were to be allocated to the award. However, less than 100% of their wages were allocated to the award.Recommendation: We recommend that PPHS implement a process to reconcile personnel costs allocated to federal awards with time and effort reports. We further recommend this process be implemented as a part of the semimonthly payroll process.Views of Responsible Officials: See attached Corrective Action Plan.
Finding 2022-006 93.268 - Immunization Cooperative Agreements Criteria CFR 200.430(i)(viii) states “budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes.” Condition The County requested reimbursement for payroll expenditures which were based on budget estimates alone. Cause The County was unaware budget estimates alone were insufficient support. Effect Payroll expenditures charged to the grant are unsupported by actual time and effort documentation. Questioned Costs $176,489 Recommendations The County should implement processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported. Views of Responsible Officials Proper policies and procedures have been created based on Federal regulations, benchmarked best practices, and applicable state statutes. Now, the focus lies with training the right employees to follow these. New procedures include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the Federal grants to ensure amounts charged are properly supported. Hood River County hopes to have all audits caught up by the end of this calendar year (2023) and be able to focus on bolstering our processes.
Finding 2022-006 93.268 - Immunization Cooperative Agreements Criteria CFR 200.430(i)(viii) states “budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes.” Condition The County requested reimbursement for payroll expenditures which were based on budget estimates alone. Cause The County was unaware budget estimates alone were insufficient support. Effect Payroll expenditures charged to the grant are unsupported by actual time and effort documentation. Questioned Costs $176,489 Recommendations The County should implement processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported. Views of Responsible Officials Proper policies and procedures have been created based on Federal regulations, benchmarked best practices, and applicable state statutes. Now, the focus lies with training the right employees to follow these. New procedures include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the Federal grants to ensure amounts charged are properly supported. Hood River County hopes to have all audits caught up by the end of this calendar year (2023) and be able to focus on bolstering our processes.
Finding 2022-006 93.268 - Immunization Cooperative Agreements Criteria CFR 200.430(i)(viii) states “budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes.” Condition The County requested reimbursement for payroll expenditures which were based on budget estimates alone. Cause The County was unaware budget estimates alone were insufficient support. Effect Payroll expenditures charged to the grant are unsupported by actual time and effort documentation. Questioned Costs $176,489 Recommendations The County should implement processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported. Views of Responsible Officials Proper policies and procedures have been created based on Federal regulations, benchmarked best practices, and applicable state statutes. Now, the focus lies with training the right employees to follow these. New procedures include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the Federal grants to ensure amounts charged are properly supported. Hood River County hopes to have all audits caught up by the end of this calendar year (2023) and be able to focus on bolstering our processes.
Finding 2022-008 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Criteria CFR 200.430(i)(viii) states “budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes.” Condition The County requested reimbursement for payroll expenditures which were based on budget estimates alone. Cause The County was unaware budget estimates alone were insufficient support. Effect Payroll expenditures charged to the grant are unsupported by actual time and effort documentation. Questioned Costs $129,786 Recommendations The County should implement processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported. Views of Responsible Officials The County is implementing processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported.
Finding 2022-008 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Criteria CFR 200.430(i)(viii) states “budget estimates alone do not qualify as support for charges to federal awards but may be used for interim accounting purposes.” Condition The County requested reimbursement for payroll expenditures which were based on budget estimates alone. Cause The County was unaware budget estimates alone were insufficient support. Effect Payroll expenditures charged to the grant are unsupported by actual time and effort documentation. Questioned Costs $129,786 Recommendations The County should implement processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported. Views of Responsible Officials The County is implementing processes and procedures to include a review of after-the-fact time and effort documentation as compared to budgeted amounts charged to the federal grants to ensure amounts charged are properly supported.
Finding 2022-010 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.268 - Immunization Cooperative Agreements Criteria According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition Internal controls were insufficient to ensure charges to the federal awards were accurate, allowable and properly allocated. Cause There has been significant turnover of County personnel in recent years, and the County has historically not been subject to Single Audit. Due to this, the County did not have a properly designed system of internal controls to ensure compliance. Effect The County charged expenditures to the grants which were unallowable. Questioned Costs None Recommendations: The County should implement a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Views of Responsible Officials A Payroll Accountant new to Hood River County in 2023 has corrected this issue in the 2024 Fiscal Year. It was thought previously that clocking in and out by function or job was not permitted by current software limitations. Two routes of correction were devised. One route for hourly employees allows now for a timecard within each individual work segment. Route two is for salaried employees which allows them to assign hours to individual segments. At the end of the pay period the employee certifies by electronic submission to their supervisor for approval. The supervisor electronically approves the timecard. Once the Payroll is processed, the Payroll Accountant looks over wage assignments by General Ledger number to ensure time is being tracked correctly. Once proofed, the Payroll Accountant then submits for the Finance Director to approve and post to the General ledger.
Finding 2022-010 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.268 - Immunization Cooperative Agreements Criteria According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition Internal controls were insufficient to ensure charges to the federal awards were accurate, allowable and properly allocated. Cause There has been significant turnover of County personnel in recent years, and the County has historically not been subject to Single Audit. Due to this, the County did not have a properly designed system of internal controls to ensure compliance. Effect The County charged expenditures to the grants which were unallowable. Questioned Costs None Recommendations: The County should implement a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Views of Responsible Officials A Payroll Accountant new to Hood River County in 2023 has corrected this issue in the 2024 Fiscal Year. It was thought previously that clocking in and out by function or job was not permitted by current software limitations. Two routes of correction were devised. One route for hourly employees allows now for a timecard within each individual work segment. Route two is for salaried employees which allows them to assign hours to individual segments. At the end of the pay period the employee certifies by electronic submission to their supervisor for approval. The supervisor electronically approves the timecard. Once the Payroll is processed, the Payroll Accountant looks over wage assignments by General Ledger number to ensure time is being tracked correctly. Once proofed, the Payroll Accountant then submits for the Finance Director to approve and post to the General ledger.
Finding 2022-010 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.268 - Immunization Cooperative Agreements Criteria According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition Internal controls were insufficient to ensure charges to the federal awards were accurate, allowable and properly allocated. Cause There has been significant turnover of County personnel in recent years, and the County has historically not been subject to Single Audit. Due to this, the County did not have a properly designed system of internal controls to ensure compliance. Effect The County charged expenditures to the grants which were unallowable. Questioned Costs None Recommendations: The County should implement a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Views of Responsible Officials A Payroll Accountant new to Hood River County in 2023 has corrected this issue in the 2024 Fiscal Year. It was thought previously that clocking in and out by function or job was not permitted by current software limitations. Two routes of correction were devised. One route for hourly employees allows now for a timecard within each individual work segment. Route two is for salaried employees which allows them to assign hours to individual segments. At the end of the pay period the employee certifies by electronic submission to their supervisor for approval. The supervisor electronically approves the timecard. Once the Payroll is processed, the Payroll Accountant looks over wage assignments by General Ledger number to ensure time is being tracked correctly. Once proofed, the Payroll Accountant then submits for the Finance Director to approve and post to the General ledger.
Finding 2022-010 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.268 - Immunization Cooperative Agreements Criteria According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition Internal controls were insufficient to ensure charges to the federal awards were accurate, allowable and properly allocated. Cause There has been significant turnover of County personnel in recent years, and the County has historically not been subject to Single Audit. Due to this, the County did not have a properly designed system of internal controls to ensure compliance. Effect The County charged expenditures to the grants which were unallowable. Questioned Costs None Recommendations: The County should implement a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Views of Responsible Officials A Payroll Accountant new to Hood River County in 2023 has corrected this issue in the 2024 Fiscal Year. It was thought previously that clocking in and out by function or job was not permitted by current software limitations. Two routes of correction were devised. One route for hourly employees allows now for a timecard within each individual work segment. Route two is for salaried employees which allows them to assign hours to individual segments. At the end of the pay period the employee certifies by electronic submission to their supervisor for approval. The supervisor electronically approves the timecard. Once the Payroll is processed, the Payroll Accountant looks over wage assignments by General Ledger number to ensure time is being tracked correctly. Once proofed, the Payroll Accountant then submits for the Finance Director to approve and post to the General ledger.
Finding 2022-010 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.268 - Immunization Cooperative Agreements Criteria According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition Internal controls were insufficient to ensure charges to the federal awards were accurate, allowable and properly allocated. Cause There has been significant turnover of County personnel in recent years, and the County has historically not been subject to Single Audit. Due to this, the County did not have a properly designed system of internal controls to ensure compliance. Effect The County charged expenditures to the grants which were unallowable. Questioned Costs None Recommendations: The County should implement a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Views of Responsible Officials A Payroll Accountant new to Hood River County in 2023 has corrected this issue in the 2024 Fiscal Year. It was thought previously that clocking in and out by function or job was not permitted by current software limitations. Two routes of correction were devised. One route for hourly employees allows now for a timecard within each individual work segment. Route two is for salaried employees which allows them to assign hours to individual segments. At the end of the pay period the employee certifies by electronic submission to their supervisor for approval. The supervisor electronically approves the timecard. Once the Payroll is processed, the Payroll Accountant looks over wage assignments by General Ledger number to ensure time is being tracked correctly. Once proofed, the Payroll Accountant then submits for the Finance Director to approve and post to the General ledger.
Assistance Listings number and name: 12.401 National Guard Military Operations and Maintenance (O&M) Projects Award numbers and years: W912L2-21-2-1000, October 1, 2020 through September 30, 2021; W912L2-22-2-1000, October 1, 2021 through September 30, 2022 Federal agency: U.S. Department of Defense Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $125,288 Condition—Contrary to federal regulations and its policies, the Department of Emergency Military Affairs (Department) did not always retain documentation supporting the payroll costs it charged to the program. Specifically, the Department had not retained the personnel action forms supporting and approving employees’ pay rates and authorizing them to work on the program for 4 of 21 employees we tested, as follows: • $123,968 for 3 employees’ annual payroll costs and employee-related expenses for which each employee’s salaries and wages and authorization to work on the program were not supported by documented personnel action forms. • $1,320 for 1 employee whose previous personnel action form authorized their working on the program but whose most recent pay rate increase was not supported by a documented personnel action form. Effect—The Department’s failure to retain documentation supporting payroll costs could potentially result in the Department being required to return monies spent on unallowable costs to the federal agency or adjust its program’s costs so that monies are spent for allowable costs.1 During fiscal year 2022, the Department paid 323 employees $15,486,984 of salaries and wages, including employee-related expenses, that were charged to the program. There is a risk that the Department could have potentially charged additional payroll costs to the program without maintaining the required supporting documentation. Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—The Department’s Administrative Services Office (Office) was not adequately trained to follow the documentation and record retention policy. Specifically, the Office reported that it did not retain the personnel action records as they were unaware that all employee personnel records were required to be retained for 5 years after an employee’s termination. Instead, the Office interpreted the policy to only require these documents to be retained for 5 years after the documents were originally created. Criteria—The Department’s record retention policies require its Administrative Services Office to retain for 5 years after an employee’s termination all the employee’s employment records, including personnel action forms authorizing employee pay rate changes and program assignments.2 Federal regulation requires the Department to retain all records related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334). Also, federal regulation requires the Department to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed and are supported by policies and internal controls to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[i][1][i]). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Ensure documentation is retained for all personnel actions to demonstrate employees’ salaries and wages, including employee-related expenses, are authorized to be charged to the program. 2. Review all employee personnel files for employees currently paid under the program to ensure the required documentation has been retained. If the documentation has not been retained, program management should review the employees’ activities to ensure they are allowable under the program and prepare and retain the required documentation. Further, if employee activities are determined to be unallowable, coordinate with the U.S. Department of Defense to adjust future federal reimbursement requests or repay any unallowable costs the Department charged to the program. 3. Train its Administrative Services Office and Department employees who are responsible for administering federal programs on the documentation and record retention requirements for payroll costs charged to federal programs. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Arizona Department of Emergency Military Affairs (DEMA), State Human Resources Administration. (2007, October). DEMA Directive 20.1, section 1.3. Retrieved 9/13/2023 from https://dema.az.gov/sites/default/files/2023-08/20.1_State_Human_Resources_Administration_20071001.pdf.