Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Names: U.S. National Aeronoautics and Space Adminstration; U.S. Department of Agriculture; U.S. Department of Defense; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of Transportation; U.S. Department of Commerce; U.S. Environmental Protection Agency; U.S. Department of Homeland Security; U.S. Department of Interior; and National Science Foundation Federal Award Numbers: Various – as listed on the Schedule Federal Award Years: Various Federal Assistance Listing Numbers: Various – as listed on the Schedule Compliance Requirement: Allowable costs/Cost principles Criteria In accordance with 2 CFR 200.303(a), non-federal entities 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. Additionally, 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Conditions Found The University performs certain manual calculations (total supplemental pay authorization divided by the number of pay periods over the summer as well as percentage allocations to multiple awards) to determine the amount to pay each pay period for both faculty and graduate assistants who work on Research and Development Cluster awards. During our testing of internal controls and compliance related to allowable costs/cost principles specific to payroll, we determined that internal controls were not designed at a level of precision to prevent or detect clerical errors associated with the manual calculations and the manual processing of payroll allocations to Research and Development Cluster awards. As a result, there were 14 errors in our sample of 81 transactions related to errors in the manual calculations, however only 7 of the errors resulted in overcharges to federal awards. The following were those errors that resulted in overcharges to federal awards: Federal assistance listing Payroll Fringe Indirect number Award number amount amount amount Total 12.300 N00014-21-1-2057 $ 170 — 90 260 13.300 N00014-21-1-2057 170 — 90 260 14.300 N00014-21-1-2057 1,425 — 755 2,180 47.041 2003307 5,744 439 3,044 9,227 47.076 1936144 7 1 4 12 47.076 2050074 10 1 5 16 47.076 1852820 20 2 11 33 $ 7,546 443 3,999 11,988 Cause In discussing these conditions with the University, they stated the errors primarily stem from when there are multiple supplemental pay authorizations or superseding appointments that require a manual calculation of the pay per pay period, retroactive adjustments or changes in allocations to federal awards. There was no secondary review of such manual calculations by someone other than the preparer. The University did not have a system of internal control that was designed and operating at a level of precision to prevent or detect errors in manual calculations and other clerical errors associated with calculations and payroll allocations for Research and Development Cluster awards related to supplemental summer payroll and graduate assistant appointments. Effect Ineffective controls could result in unallowable costs being charged to the Research and Development Cluster awards. Questioned Costs $11,988 which includes payroll, fringe benefits and applicable indirect costs. Statistical Sample Our sample was not, and was not intended to be statistically valid. Repeat Finding This finding is a repeat finding – see prior year finding 2021-003. Recommendation We recommend the University design and implement a more precise system of internal control to ensure manual calculations and payroll allocations for Research and Development Cluster awards are accurate and an allowable cost prior to processing payroll and recording payroll allocations.
2022-005 – Delayed Approval of Compensation Rates (SD) Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Category of Finding: Allowable Costs and Cost Principles Criteria: Per 2 CFR §200.430 of the Uniform Guidance, compensation for personnel services, including any adjustments, must be based on documented and approved procedures in accordance with the organization’s established policies. All changes to compensation must be approved and documented in a timely manner to ensure compliance with both federal and non-federal funding requirements. The City uses personnel action forms (PAF) to document changes to compensation. The PAF must be approved by authorized personnel in advance. Condition: During the review of personnel costs, it was observed that changes in the compensation rates for employees charged to the federally funded project were not approved in a timely manner. Documentation showed delays in the authorization of salary adjustments, with compensation changes becoming effective before formal approval by the City. Cause: The City’s internal control processes for reviewing and approving compensation changes were not followed promptly. There was a lack of procedures ensuring that salary adjustments were approved prior to the effective date. Effect or Potential Effect: Untimely approval of compensation changes increases the risk of inaccurate or unallowable personnel costs being charged to the federal award. This may result in questioned costs, non-compliance with federal regulations, and potential audit findings. Questioned Cost: None. Context: We selected five employees who worked on the program and in all cases, the PAF were authorized much later than the effective date of the compensation change. Statistical Sampling Validity: More than 50% of employees who work on the program were selected. Repeat of a Prior-Year Finding: No. Recommendation: The City should reinforce internal controls to ensure that all compensation changes are reviewed and approved promptly. This should include: • Establishing a timeline for the approval of compensation adjustments. • Implementing procedures that prevent compensation changes from being applied until formal approval is obtained. • Ensuring proper documentation of all approved salary changes is maintained. Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The HR and payroll policies will be updated to incorporate the above recommendations. Planned Implementation Date: March 2025 Responsible Person(s): City Manager
2022-004 Allocation of Program Effort by Employees – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program: Research and Development Cluster (ALN 47.041, Award Period 9/1/19 – 8/31/22) Federal Agency: National Science Foundation Criteria: The financial management requirements include processes and controls over the allocation of personnel time and effort to program activities as required by 2 CFR 200.430. Condition: Our testing of payroll expenses charged to the program noted that the Organization allocates senior personnel time and effort in one year end journal entry as a program expense. Upon review of the supporting documentation for the journal entry, it was noted that one individual included in the allocation was no longer an employee of the Organization during the year ended June 30, 2022. Cause: The Organization lacks written policies, approval procedures and documentation to allocate senior personnel effort and time costs to program accounting records. Effect: The Organization does not maintain a compliant effort system and is not in compliance with 2 CFR 200.430 which could lead to inaccurate allocation of personnel costs to the federal program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2021-005 in the prior year. Recommendation: We recommend the Organization strengthen its controls and processes over time and effort allocations by establishing written policies, timesheet allocations, approvals and segregation of duties in compliance with 2 CFR 200.430. Response: The Organization will improve its procedures for allocating senior personnel time and effort in its accounting and financial record keeping processes. Questioned Costs: $10,000 – Based on the support for the journal entry, this is the amount allocated for the individual that was no longer an employee of the Organization during the year ended June 30, 2022.
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: $23,398 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Title I Grants to Local Educational Agencies program. Background: The Title I Grants to Local Educational Agencies (Title I) program was authorized under the Elementary and Secondary Education Act of 1965 to help local educational agencies (LEAs) improve teaching and learning in high-poverty schools in particular for children failing or most at-risk of failing, to meet challenging State academic standards. LEAs may operate targeted assistance programs in which children who are failing or most at-risk of failing may be served or schoolwide programs in which all children in eligible schools may be served. Title I funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. Title I funds totaling $377,570 were expended and reported on the Talbot County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity…” Condition: Three individually significant non-personal services expenditures were selected for testing to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. For one individually significant expenditure in the amount of $19,848, adequate supporting documentation in the form of an invoice was not maintained. Additionally, a sample of two employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. It was noted that timesheets were not maintained to evidence accuracy of amounts paid for $3,550 of additional pay. Questioned Costs: Upon testing individually significant expenditures, known questioned costs of $19,848 were identified for expenditures that were not supported by adequate documentation. These known questioned costs related to expenditures that were not tested as part of a sample and should not be projected to a population to determine likely questioned costs. Additionally, upon testing a sample of $99,999 in personal services expenditures, known questioned costs of $3,550 were identified for expenditures not supported by adequate documentation. Using the total personal services expenditures population of $200,603 (excluding benefits payments), we project the likely questioned costs to be approximately $7,121. Therefore, the known and likely questioned costs identified for all unallowable payments throughout the sample and individually significant items tested totaled $23,398 and $26,969, respectively. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the Title I program. Failure to ensure that documentation exists to support the allowability of payments from the Title I fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should review current internal control procedures related to Title I program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: $23,398 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Title I Grants to Local Educational Agencies program. Background: The Title I Grants to Local Educational Agencies (Title I) program was authorized under the Elementary and Secondary Education Act of 1965 to help local educational agencies (LEAs) improve teaching and learning in high-poverty schools in particular for children failing or most at-risk of failing, to meet challenging State academic standards. LEAs may operate targeted assistance programs in which children who are failing or most at-risk of failing may be served or schoolwide programs in which all children in eligible schools may be served. Title I funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. Title I funds totaling $377,570 were expended and reported on the Talbot County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity…” Condition: Three individually significant non-personal services expenditures were selected for testing to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. For one individually significant expenditure in the amount of $19,848, adequate supporting documentation in the form of an invoice was not maintained. Additionally, a sample of two employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. It was noted that timesheets were not maintained to evidence accuracy of amounts paid for $3,550 of additional pay. Questioned Costs: Upon testing individually significant expenditures, known questioned costs of $19,848 were identified for expenditures that were not supported by adequate documentation. These known questioned costs related to expenditures that were not tested as part of a sample and should not be projected to a population to determine likely questioned costs. Additionally, upon testing a sample of $99,999 in personal services expenditures, known questioned costs of $3,550 were identified for expenditures not supported by adequate documentation. Using the total personal services expenditures population of $200,603 (excluding benefits payments), we project the likely questioned costs to be approximately $7,121. Therefore, the known and likely questioned costs identified for all unallowable payments throughout the sample and individually significant items tested totaled $23,398 and $26,969, respectively. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the Title I program. Failure to ensure that documentation exists to support the allowability of payments from the Title I fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should review current internal control procedures related to Title I program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District’s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $611,712 were expended and reported on the Talbot County School District’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity…” III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Condition: A sample of seven non-personal services expenditures was randomly selected for testing using a non-statistical sampling approach. In addition, three individually significant items were selected for testing. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • A purchase order was not maintained for two of the expenditures. • The check amount, invoice, and purchase requisition form for one expenditure did not agree. • One expenditure was not appropriately approved by GaDOE through the Consolidated Application process. In addition, a sample of 15 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • Timesheets or other supporting documentation could not be provided for payments made to 14 employees. • Timesheets provided for six employees did not agree to amounts paid for the corresponding time period. Furthermore, upon completing testing over personal services expenditures for the Title I Grants to Local Educational Agencies (Title I) program, auditor noted that two employees were paid $2,870 from the ESSER fund that could not be supported by timesheets or other documentation. Questioned Costs: Upon testing a sample of $23,522 in non-personal service expenditures, known questioned costs of $9,424 were identified for expenditures not supported by adequate documentation or not properly approved through the Consolidated Application process. Using the total non-personal services expenditures population of $55,926, we project the likely questioned costs to be approximately $22,407. Additionally, upon testing a sample of $118,771 in personal services expenditures, known questioned costs of $46,121 were identified. Using the total personal services expenditure population of $298,264, we project the likely questioned costs to be approximately $115,821. Furthermore, known questioned costs of $2,870 were identified for unsupported ESSER payments upon completing personal services testing associated with the Title I program. Therefore, the known and likely questioned costs identified for unallowable payments totaled $58,415 and $138,228. The following Assistance Listing Number was affected by known and likely questioned costs: 84.425D. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the ESSER program. Failure to ensure that documentation exists to support the allowability of payments from the ESSER fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District’s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $611,712 were expended and reported on the Talbot County School District’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity…” III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Condition: A sample of seven non-personal services expenditures was randomly selected for testing using a non-statistical sampling approach. In addition, three individually significant items were selected for testing. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • A purchase order was not maintained for two of the expenditures. • The check amount, invoice, and purchase requisition form for one expenditure did not agree. • One expenditure was not appropriately approved by GaDOE through the Consolidated Application process. In addition, a sample of 15 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if appropriate internal controls were implemented, and applicable compliance requirements were met. The following deficiencies were noted: • Timesheets or other supporting documentation could not be provided for payments made to 14 employees. • Timesheets provided for six employees did not agree to amounts paid for the corresponding time period. Furthermore, upon completing testing over personal services expenditures for the Title I Grants to Local Educational Agencies (Title I) program, auditor noted that two employees were paid $2,870 from the ESSER fund that could not be supported by timesheets or other documentation. Questioned Costs: Upon testing a sample of $23,522 in non-personal service expenditures, known questioned costs of $9,424 were identified for expenditures not supported by adequate documentation or not properly approved through the Consolidated Application process. Using the total non-personal services expenditures population of $55,926, we project the likely questioned costs to be approximately $22,407. Additionally, upon testing a sample of $118,771 in personal services expenditures, known questioned costs of $46,121 were identified. Using the total personal services expenditure population of $298,264, we project the likely questioned costs to be approximately $115,821. Furthermore, known questioned costs of $2,870 were identified for unsupported ESSER payments upon completing personal services testing associated with the Title I program. Therefore, the known and likely questioned costs identified for unallowable payments totaled $58,415 and $138,228. The following Assistance Listing Number was affected by known and likely questioned costs: 84.425D. Cause: Per discussion with management, the School District believes that this is due to change in management in the financial department. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the ESSER program. Failure to ensure that documentation exists to support the allowability of payments from the ESSER fund may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are supported by appropriate documentation. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District’s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.
2022-004 Allocation of Program Effort by Employees – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program: Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 8/31/22) Federal Agency: National Science Foundation Criteria: The financial management requirements include processes and controls over the allocation of personnel time and effort to program activities as required by 2 CFR 200.430. Condition: Our testing of payroll expenses charged to the program noted that the Organization allocates senior personnel time and effort in one year end journal entry as a program expense. Upon review of the supporting documentation for the journal entry, it was noted that one individual included in the allocation was no longer an employee of the Organization during the year ended June 30, 2022. Cause: The Organization lacks written policies, approval procedures and documentation to allocate senior personnel effort and time costs to program accounting records. Effect: The Organization does not maintain a compliant effort system and is not in compliance with 2 CFR 200.430 which could lead to inaccurate allocation of personnel costs to the federal program. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2021-005 in the prior year. Recommendation: We recommend the Organization strengthen its controls and processes over time and effort allocations by establishing written policies, timesheet allocations, approvals and segregation of duties in compliance with 2 CFR 200.430. Response: The Organization will improve its procedures for allocating senior personnel time and effort in its accounting and financial record keeping processes. Questioned Costs: $10,000 – Based on the support for the journal entry, this is the amount allocated for the individual that was no longer an employee of the Organization during the year ended June 30, 2022.
Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation for exempt employees' hours was unavailable or incomplete. Cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. Effect or potential effect: During our testing over payroll, we noted $3,875 of exempt employee salary expense that was not supported with accurate time records. This amount projects to a possible total error of $91,107. Questioned cost: $91,107 Recommendation: We recommend that management to regularly review the actual hours that exempt employees worked to determine the amount of time that’s being allocated by the exempt employees represent accurate estimated hours. Views of responsible officials: Behavioral Health Services, Inc. acknowledges the finding identified in the 2022 Single Audit and is committed to addressing the issue to ensure compliance and improve internal controls. The following corrective actions will be implemented: - Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. - Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. Views of responsible officials: - Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. - Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions.
Criteria: Under the Uniform Guidance, specifically 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Documentation for exempt employees' hours was unavailable or incomplete. Cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. Effect or potential effect: During our testing over payroll, we noted $13,097 of exempt employee salary expense that was not supported with accurate time records. This amount projects to a possible total error of $276,370. Questioned cost: $276,370 Recommendation: We recommend that management to regularly review the actual hours that exempt employees worked to determine the amount of time that’s being allocated by the exempt employees represent accurate estimated hours. Views of responsible officials: Behavioral Health Services, Inc. acknowledges the finding identified in the 2022 Single Audit and is committed to addressing the issue to ensure compliance and improve internal controls. The following corrective actions will be implemented: - Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. - Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. - Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. - Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services Federal Grant/Contract Number: 10CH011215-02; 10CH011215-03; 10HE000901-01 Grant period – 2021 & 2022 Criteria – Per 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; paragraph (g) Be adequately documented. Per 2 CFR section 200.404 – Reasonable costs – A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Per 2 CFR section 200.405 – Allocable costs –focuses on how costs are allocable, ensuring they are directly tied to the federal award or its benefits. Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and that are incorporated into the official records of the non-Federal entity. Condition – The following exceptions were noted during testing of 138 program disbursements, 93 payroll disbursements, and 100 journal entry transactions: • 20 invoices could not be located related to program disbursements • 6 invoices tested did not agree to the approved allocation of Head Start expenses • 1 timecard could not be located • multiple instances where an approved pay rate covering the appropriate time-period could not be obtained • 12 instances where supporting documentation for journal entries to adjust Head Start expenses could not be obtained. Cause – Turnover in staff and the passage of time since the period under audit has caused documentation to be misplaced. Effect – Inadequate or inconsistent documentation of expenses may result in erroneous or fraudulent transactions occurring, loss of funding, or disallowed costs. Questioned Costs – $151,608. Recommendation – Documentation should be prepared, reviewed, and retained to support the expense. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.
2022-002 Improve Controls and Documentation Over Payroll Federal Agency: U.S. Department of Education Award Name: COVID-19 – Education Stabilization Fund AL Number(s): 84.425 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement In accordance with 2 CFR § 200.430 and program requirements for the Education Stabilization Fund, payroll costs charged to federal awards must be supported by appropriate documentation, such as approved pay rates. Costs must relate to approved activities, be allowable under the grant, and be supported by the City’s payroll records. Additionally, for transfers or allocations of payroll costs, documentation of the transfer or allocation to the federal grant must be maintained. Condition and Context During our testing of 22 payroll transactions charged to the ESSER grant, pay rate documentation supporting the amounts charged to the grant was not provided for 16 employees. Further, for 10 employees receiving summer enrichment stipends, the City was unable to provide evidence of the balance transfer of stipend costs to the ESSER grant. Cause The City did not maintain or was unable to provide the required payroll documentation, such as pay rates, and did not retain evidence of payroll balance transfers or allocations to the ESSER grant for summer enrichment stipends. This indicates a lack of effective internal controls over payroll documentation and grant cost allocations. Effect or Potential Effect Without supporting documentation for pay rates, there is an increased risk that amounts charged to the grant may be incorrect or unallowable. Failure to document transfers or allocations to the grant could result in improper charging of costs, questioned costs, or noncompliance with federal regulations. Questioned Costs Due to the condition noted, we were unable to determine if the costs charged to the grant were allowable. AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.425 COVID-19 – Education Stabilization Fund $31,493 Recommendation The City should develop and implement policies and procedures to ensure that documentation supporting pay rates and payroll allocations is retained and readily available for all grant-funded employees. The City should also ensure that all transfers and allocations of payroll costs to federal grants are properly documented, reviewed, and approved. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
We identified the following Other Matter related to internal controls over federal awards: 2022-002 Documentation of Timesheet Review Federal Program: HIV Emergency Relief Project Grants CFDA Number: 93.914 Federal Agency: U.S. Department of Health and Human Services Year: 2022 Questioned Costs: $0 Criteria: 2 CFR 200.430, Compensation ? personal services, states, in part: ?(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;? Condition We reviewed a sample of employee timesheets and approvals were not documented either by paper or system electronic approvals. Recommendation We recommend the Center review timesheets and document timesheet review either by documenting it in paper or by system electronic approvals.
We identified the following Other Matter related to internal controls over federal awards: 2022-002 Documentation of Timesheet Review Federal Program: HIV Emergency Relief Project Grants CFDA Number: 93.914 Federal Agency: U.S. Department of Health and Human Services Year: 2022 Questioned Costs: $0 Criteria: 2 CFR 200.430, Compensation ? personal services, states, in part: ?(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;? Condition We reviewed a sample of employee timesheets and approvals were not documented either by paper or system electronic approvals. Recommendation We recommend the Center review timesheets and document timesheet review either by documenting it in paper or by system electronic approvals.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ During our review of payroll related transactions, the following were noted For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period. For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period. For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs –$1,010 Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Controls were put in place during the year but were not consistently followed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ During our review of payroll related transactions, the following were noted For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period. For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period. For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs –$1,010 Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Controls were put in place during the year but were not consistently followed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ During our review of payroll related transactions, the following were noted For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period. For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period. For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs –$1,010 Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Controls were put in place during the year but were not consistently followed.
#2021-002 – Material Weakness – Allowable Costs/Cost Principles Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.430 states, “Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition During the course of the audit, we noted that the Organization used an allocation methodology to allocate salaries to the federal award based upon time spent on the program. However, for eleven of the employees, there were no timesheets to support the amount of time allocated to the Organization’s grant programs. Cause The cause is a lack of proper internal controls which would require the Organization to maintain adequate support for time spent on grant programs and a formal allocation process to allocate payroll costs across the grant programs. Effect The potential effects of not having supporting documentation for the allocation of payroll expenses is potential overbilling of expenses to the grant program. Questioned Costs $33,316 Perspective Information We reviewed a sample of monthly reports filed with the Pennsylvania Department of Military and Veterans Affairs and the Drug and Alcohol Program. We examined the payroll for each employee charged to the grant for a total of twenty-six employees. The finding is related to eleven individuals who did not complete timesheets or provide supporting documentation for the amount of time spent on the Organization’s grant programs. Identification as a repeat finding A similar issue was noted in prior year finding #2020-002. Recommendation We recommend that the Organization require timesheets for the hours allocated to the grant programs for all employees whether they are salary or hourly to ensure that the payroll charged to grants is accurate and properly supported. View of responsible officials and planned corrective action Starting in 2023 all employees of the Organization will complete formal time sheets. These sheets will be signed by the Administrative Coordinator and by the Fiscal Coordinator and then entered into the system each pay period to rectify this finding.
#2021-003 – Material Weakness – Activities Allowed or Unallowed Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. In accordance with CFR 200.430, payroll costs charged to the program are allowable when: the total compensation paid to individual employees is reasonable according to the work performed on the program and the compensation is in accordance with the established policies of the organization. Condition During the audit we noted the Organization does not have established policies and procedures over payroll. We noted that while the Organization has established hourly and salary pay rates, these rates are not formally established and approved by the Organization’s Board. Cause The cause is a lack of a proper control structure that requires Board approval of pay rates and salaries. The Organization also does not have a process in place to ensure that payroll reports are properly reviewed and approved by a second independent reviewer prior to submission to the payroll company for processing. Effect The potential effects of not having formally approved pay rates and not having payroll reports reviewed by a second level prior to payroll processing is the potential for errors and overcharging of grants. Questioned Costs None Perspective Information We reviewed a sample of reports filed with the Pennsylvania Department of Military and Veterans Affairs and the Drug and Alcohol Program. We examined the payroll for each employee charged to the grant for a total of twenty-six employees. The finding represents the unsupported costs noted from this review. Identification as a repeat finding A similar issue was noted in prior year finding #2020-003. Recommendation We recommend that the Organization begin to formally establish and approve employee pay rates and salaries at Official Board Meetings and that these rates are documented in the Board Minutes. The Organization should also implement procedures to include a second level review of the payroll report for accuracy and completeness prior to submission for payment. View of responsible officials and planned corrective action JFT does have all the board minutes on file. However, because we were a small agency, salary rates were not often changed. Additionally, all salary rates and changes were always driven by the ability to obtain the funding needed. Since we were small and there was not always a lot to discuss with the board our board only met twice a year. Therefore, all salary was discussed with the board president, then taken to the board unfortunately there is no formal documentation at this time. As of 2023 our board now meets quarterly. Therefore, the following policy will be included in the fiscal manual: the JFT board of directors will hold a public meeting quarterly. All matters of pay rates and salaries will be approved at the start of each grant cycle. State and county grants will be discussed prior to the July 1 start dates, all federal will be discussed prior to October 1. Any changes in salary must be approved by the board and documented in official board minutes. All board minutes will be placed in a lock file in the Fiscal Coordinator’s office.