FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 30 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Education Stabilization Fund established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. Costs charged to grant funds must be adequately documented. To adequately document payroll expenses charged to the grant fund, contracts or other documentation supporting the employees' approved rates of pay are necessary. The School Corporation utilized a financial software system that has two different sides, an employee portal side and an administrator side. Employee contracts are approved by the employee, the Superintendent of Schools, and the President of the School Board within the system on the employee portal side. Once approved, the data in the employee portal side is fed into a process in the administrator side. The School Corporation could not provide contracts for 3 of 13 employees tested, as the contracts were not properly archived in the financial software used to electronically approve and archive employment contracts. As such, we could not verify the employees were paid their contracted rate for hours spent working on grant-related activities. This resulted in known questioned costs of $26,207. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, 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. INDIANA STATE BOARD OF ACCOUNTS 31 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all employment contracts could be presented for audit nor could documentation be provided to support time charged to the grant. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were known questioned costs of $26,207 as identified in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contracts and certifications, as appropriate, are retained to support the amounts paid from Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 32 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response The alternative documentation provided was a snapshot from the administrator side of the financial software system; however, the original source document, which was the contract that was approved by the employee, the Superintendent of Schools, and the President of the School Board, was not provided to substantiate the amounts in the administrator side of the financial software system. We reaffirm our finding and will review the status of the finding during our next audit.
FINDING 2022-006 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 30 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Education Stabilization Fund established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. Costs charged to grant funds must be adequately documented. To adequately document payroll expenses charged to the grant fund, contracts or other documentation supporting the employees' approved rates of pay are necessary. The School Corporation utilized a financial software system that has two different sides, an employee portal side and an administrator side. Employee contracts are approved by the employee, the Superintendent of Schools, and the President of the School Board within the system on the employee portal side. Once approved, the data in the employee portal side is fed into a process in the administrator side. The School Corporation could not provide contracts for 3 of 13 employees tested, as the contracts were not properly archived in the financial software used to electronically approve and archive employment contracts. As such, we could not verify the employees were paid their contracted rate for hours spent working on grant-related activities. This resulted in known questioned costs of $26,207. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, 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. INDIANA STATE BOARD OF ACCOUNTS 31 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, not all employment contracts could be presented for audit nor could documentation be provided to support time charged to the grant. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were known questioned costs of $26,207 as identified in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contracts and certifications, as appropriate, are retained to support the amounts paid from Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 32 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response The alternative documentation provided was a snapshot from the administrator side of the financial software system; however, the original source document, which was the contract that was approved by the employee, the Superintendent of Schools, and the President of the School Board, was not provided to substantiate the amounts in the administrator side of the financial software system. We reaffirm our finding and will review the status of the finding during our next audit.
FA 2022-001 Improve Controls over Employee Compensation Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $41,310 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $987,385.00 were expended and reported on the Hancock 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…” 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: Auditors reviewed salaries for a randomly selected sample of employees and those employees who were paid over the individually significant item threshold for CNC. These employees were reviewed to determine if internal controls were properly functioning and applicable compliance requirements were met. Testing of these salaries revealed that the former School Food Service Director’s salary was paid from Child Nutrition Cluster funds while the employee had moved to another position within the School District and did not perform Child Nutrition Cluster services. Questioned Costs: Known questioned costs of $41,310 were identified for salaries charged to the Child Nutrition Cluster in error. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: The former Child Nutrition Director changed to a different position and was not correctly removed from the Child Nutrition Cluster payroll for the year under review. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees associated with the Child Nutrition Cluster the appropriate amount and/or maintain documentation supporting these payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the Child Nutrition Cluster fund as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control processes regarding the retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are appropriately documented and to ensure that Child Nutrition Cluster employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Employee Compensation Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $41,310 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $987,385.00 were expended and reported on the Hancock 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…” 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: Auditors reviewed salaries for a randomly selected sample of employees and those employees who were paid over the individually significant item threshold for CNC. These employees were reviewed to determine if internal controls were properly functioning and applicable compliance requirements were met. Testing of these salaries revealed that the former School Food Service Director’s salary was paid from Child Nutrition Cluster funds while the employee had moved to another position within the School District and did not perform Child Nutrition Cluster services. Questioned Costs: Known questioned costs of $41,310 were identified for salaries charged to the Child Nutrition Cluster in error. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: The former Child Nutrition Director changed to a different position and was not correctly removed from the Child Nutrition Cluster payroll for the year under review. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees associated with the Child Nutrition Cluster the appropriate amount and/or maintain documentation supporting these payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the Child Nutrition Cluster fund as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control processes regarding the retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are appropriately documented and to ensure that Child Nutrition Cluster employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Employee Compensation Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $41,310 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $987,385.00 were expended and reported on the Hancock 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…” 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: Auditors reviewed salaries for a randomly selected sample of employees and those employees who were paid over the individually significant item threshold for CNC. These employees were reviewed to determine if internal controls were properly functioning and applicable compliance requirements were met. Testing of these salaries revealed that the former School Food Service Director’s salary was paid from Child Nutrition Cluster funds while the employee had moved to another position within the School District and did not perform Child Nutrition Cluster services. Questioned Costs: Known questioned costs of $41,310 were identified for salaries charged to the Child Nutrition Cluster in error. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: The former Child Nutrition Director changed to a different position and was not correctly removed from the Child Nutrition Cluster payroll for the year under review. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees associated with the Child Nutrition Cluster the appropriate amount and/or maintain documentation supporting these payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the Child Nutrition Cluster fund as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control processes regarding the retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are appropriately documented and to ensure that Child Nutrition Cluster employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Employee Compensation Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $41,310 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $987,385.00 were expended and reported on the Hancock 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…” 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: Auditors reviewed salaries for a randomly selected sample of employees and those employees who were paid over the individually significant item threshold for CNC. These employees were reviewed to determine if internal controls were properly functioning and applicable compliance requirements were met. Testing of these salaries revealed that the former School Food Service Director’s salary was paid from Child Nutrition Cluster funds while the employee had moved to another position within the School District and did not perform Child Nutrition Cluster services. Questioned Costs: Known questioned costs of $41,310 were identified for salaries charged to the Child Nutrition Cluster in error. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: The former Child Nutrition Director changed to a different position and was not correctly removed from the Child Nutrition Cluster payroll for the year under review. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees associated with the Child Nutrition Cluster the appropriate amount and/or maintain documentation supporting these payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the Child Nutrition Cluster fund as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control processes regarding the retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are appropriately documented and to ensure that Child Nutrition Cluster employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: We concur with this finding.
Allowable Costs/Cost Principles - Payroll Allocations Finding Type: Significant Deficiency in Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323). Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples. Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430. Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent. Questioned Costs: $15,701 (known), $94,514 (likely). Repeat finding: No. Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations Finding Type: Significant Deficiency in Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323). Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples. Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430. Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent. Questioned Costs: $15,701 (known), $94,514 (likely). Repeat finding: No. Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations Finding Type: Significant Deficiency in Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323). Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples. Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430. Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent. Questioned Costs: $15,701 (known), $94,514 (likely). Repeat finding: No. Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations Finding Type: Significant Deficiency in Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323). Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples. Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430. Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent. Questioned Costs: $15,701 (known), $94,514 (likely). Repeat finding: No. Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations Finding Type: Significant Deficiency in Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323). Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples. Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430. Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent. Questioned Costs: $15,701 (known), $94,514 (likely). Repeat finding: No. Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Finding Number: 2022-005 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Award #: Various Award Year: 03/03/2021 – 12/31/2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated. Questioned Costs – Not determinable. Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Payroll expense were not properly calculated and captured in the accounting system. Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-005 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Award #: Various Award Year: 03/03/2021 – 12/31/2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated. Questioned Costs – Not determinable. Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Payroll expense were not properly calculated and captured in the accounting system. Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-005 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Award #: Various Award Year: 03/03/2021 – 12/31/2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated. Questioned Costs – Not determinable. Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Payroll expense were not properly calculated and captured in the accounting system. Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-005 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Award #: Various Award Year: 03/03/2021 – 12/31/2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated. Questioned Costs – Not determinable. Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Payroll expense were not properly calculated and captured in the accounting system. Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-005 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Award #: Various Award Year: 03/03/2021 – 12/31/2024 Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: • Be incorporated into the organization’s official records; • Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and • Support the distribution of employee salary across multiple activities or cost objectives. Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated. Questioned Costs – Not determinable. Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – Payroll expense were not properly calculated and captured in the accounting system. Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Noncompliance/Material Weakness – Questioned Cost 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The District recorded and expenditure adjustment reclassifying payroll and benefit expenditures from the General Fund to the Special Education – Grants to State (IDEA, Part B) in the amount $209,856. The District was not able to provide which employees these expenses related to, therefor no documentation existed to conclude that the expenditures related to special education activities. The $209,856 from Special Education – Grants to State (IDEA, Part B) is considered a questioned cost. Failure to maintain the appropriate clear and concise supporting documentation for infrequent and unusual transaction could result in questioned costs and reduced future federal funding or the requirement to repay the Ohio Department of Education and Workforce. We recommend the District implement additional control procedures that ensure any expenditure adjustment maintains adequate supporting documentation.
Noncompliance/Material Weakness – Questioned Cost 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The District recorded and expenditure adjustment reclassifying payroll and benefit expenditures from the General Fund to the Special Education – Grants to State (IDEA, Part B) in the amount $209,856. The District was not able to provide which employees these expenses related to, therefor no documentation existed to conclude that the expenditures related to special education activities. The $209,856 from Special Education – Grants to State (IDEA, Part B) is considered a questioned cost. Failure to maintain the appropriate clear and concise supporting documentation for infrequent and unusual transaction could result in questioned costs and reduced future federal funding or the requirement to repay the Ohio Department of Education and Workforce. We recommend the District implement additional control procedures that ensure any expenditure adjustment maintains adequate supporting documentation.
Noncompliance/Material Weakness – Questioned Cost 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The District recorded and expenditure adjustment reclassifying payroll and benefit expenditures from the General Fund to the Special Education – Grants to State (IDEA, Part B) in the amount $209,856. The District was not able to provide which employees these expenses related to, therefor no documentation existed to conclude that the expenditures related to special education activities. The $209,856 from Special Education – Grants to State (IDEA, Part B) is considered a questioned cost. Failure to maintain the appropriate clear and concise supporting documentation for infrequent and unusual transaction could result in questioned costs and reduced future federal funding or the requirement to repay the Ohio Department of Education and Workforce. We recommend the District implement additional control procedures that ensure any expenditure adjustment maintains adequate supporting documentation.
Noncompliance/Material Weakness – Questioned Cost 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The District recorded and expenditure adjustment reclassifying payroll and benefit expenditures from the General Fund to the Special Education – Grants to State (IDEA, Part B) in the amount $209,856. The District was not able to provide which employees these expenses related to, therefor no documentation existed to conclude that the expenditures related to special education activities. The $209,856 from Special Education – Grants to State (IDEA, Part B) is considered a questioned cost. Failure to maintain the appropriate clear and concise supporting documentation for infrequent and unusual transaction could result in questioned costs and reduced future federal funding or the requirement to repay the Ohio Department of Education and Workforce. We recommend the District implement additional control procedures that ensure any expenditure adjustment maintains adequate supporting documentation.
Noncompliance/Material Weakness – Questioned Cost 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The District recorded and expenditure adjustment reclassifying payroll and benefit expenditures from the General Fund to the Special Education – Grants to State (IDEA, Part B) in the amount $209,856. The District was not able to provide which employees these expenses related to, therefor no documentation existed to conclude that the expenditures related to special education activities. The $209,856 from Special Education – Grants to State (IDEA, Part B) is considered a questioned cost. Failure to maintain the appropriate clear and concise supporting documentation for infrequent and unusual transaction could result in questioned costs and reduced future federal funding or the requirement to repay the Ohio Department of Education and Workforce. We recommend the District implement additional control procedures that ensure any expenditure adjustment maintains adequate supporting documentation.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee’s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management’s views and corrective action plan is included in a separate corrective action plan.