Finding 2020-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Treasury Federal Programs: Coronavirus Relief Fund CFDA Numbers: 21.019 Award Number: SLT0591/0845/1405 Award Year: 2020 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our testing of payroll transactions charged to the program, we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. Additionally, we noted that nearly all employees tested did not have approved pay rates in their personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In all cases noted, the employees were under paid. Repeat finding: This is a repeat of Finding 2019-009, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2020-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Treasury Federal Programs: Coronavirus Relief Fund CFDA Numbers: 21.019 Award Number: SLT0591/0845/1405 Award Year: 2020 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our testing of payroll transactions charged to the program, we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. Additionally, we noted that nearly all employees tested did not have approved pay rates in their personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In all cases noted, the employees were under paid. Repeat finding: This is a repeat of Finding 2019-009, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2020-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Treasury Federal Programs: Coronavirus Relief Fund CFDA Numbers: 21.019 Award Number: SLT0591/0845/1405 Award Year: 2020 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our testing of payroll transactions charged to the program, we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. Additionally, we noted that nearly all employees tested did not have approved pay rates in their personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In all cases noted, the employees were under paid. Repeat finding: This is a repeat of Finding 2019-009, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2020-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Treasury Federal Programs: Coronavirus Relief Fund CFDA Numbers: 21.019 Award Number: SLT0591/0845/1405 Award Year: 2020 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our testing of payroll transactions charged to the program, we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. Additionally, we noted that nearly all employees tested did not have approved pay rates in their personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In all cases noted, the employees were under paid. Repeat finding: This is a repeat of Finding 2019-009, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2020-005 - Material Weakness - Missing Supporting Documentation CFDA Number and Title: 84.287 Twenty-First Century Community Learning Centers Applicable Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: According to 2 CFR §200.430(i), charges to federal awards for salaries 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. Additionally, the Twenty-First Century Community Learning Centers program requires grantees to maintain documentation that supports personnel costs charged to the grant, including time and effort records for staff funded in whole or in part by federal funds. Condition: During the audit of expenditures under the Twenty-First Century Community Learning Centers program pay records, such as timesheets, pay rates or equivalent documentation, which support time and effort charged to the grant were not available for review. The missing files had been stored on a drive maintained by a former employee and could not be recovered. Cause: The City did not retain or migrate payroll documentation from the former employee’s system, resulting in the loss of critical records necessary to support grant expenditures. Effect or Potential Effect: Without adequate documentation, the organization cannot substantiate the allowability of payroll costs charged to the 21st CCLC grant. This may result in questioned costs and potential repayment or corrective action requirements from the granting agency. Questioned Costs: $120,064 represent salaries charged to the grant where no timesheets could be provided. Context: The ten missing timesheets were for specific pay periods throughout the fiscal year. The questioned costs represent those employee’s salaries charged to the grant for the year. Recommendation: The City should establish and enforce a formal records retention policy that ensures all grant-related documentation, including payroll and time and effort records, is preserved and accessible. Additionally, procedures should be implemented to verify that personnel costs charged to the grant comply with federal requirements and program-specific guidance. Management’s Responses: See corrective action plan.
Criteria: The requirements for allowable costs related to wages and salaries are contained in 2 CFR Section 200.430. This states that salaries and wages charged to federal awards 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 year under audit, PAX did not have a time and effort reporting system that met the requirements of the federal cost principles. Citation: 2 CFR 200.430 Cause: PAX did not have an effective internal control system in place for monitoring and documenting wages and salaries charged to the federal awards. Effect: PAX did not maintain adequate documentation to support salaries charged to the federal awards throughout the year. However, they provided attestations and other support to demonstrate that the salaries and wages were accurate, allowable, and properly allocated after year-end as part of the audit process. Questioned Costs: PAX charged $1,109,466 of wages and salaries to the major program. Context: This was a universal matter that impacted the entity as a whole. Repeat Finding: No Recommendation: We recommend that management establish internal control process, such as a time sheet reporting system, to capture which grant each employee spends time on. View of Responsible Officials: See Corrective Action Plan attached.
Criteria: • • §2 CFR 200.430 (i) Standards for Documentation of Personnel Expenses, establishes that “(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;” • • The Human Resources manuals that establish the hire procedures for the employee’s Authority, in its article 6.2 Job Description, establishes that the Authority shall prepare and keep up to date, for each authorized position in the career service, a clear and precise description of the essential and marginal duties and responsibilities, degree of authority, responsibility and supervision assigned to it. Condition: Four (4) employees, out of a sample of fifteen (15) files examined, had no job descriptions. Cause: The Program did not follow up the established procedures for hiring of personnel. Effects: Condition may result in noncompliance with the requirements of record retention and with internal controls as in place for COR3. Questioned Costs: None Recommendation: We recommended management to monitor the implementation of procedures in place to maintain updated employee’s personal file.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Criteria: • • §2 CFR 200.430 (i) Standards for Documentation of Personnel Expenses, establishes that “(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;” • • The Human Resources manuals that establish the hire procedures for the employee’s Authority, in its article 6.2 Job Description, establishes that the Authority shall prepare and keep up to date, for each authorized position in the career service, a clear and precise description of the essential and marginal duties and responsibilities, degree of authority, responsibility and supervision assigned to it. Condition: Four (4) employees, out of a sample of fifteen (15) files examined, had no job descriptions. Cause: The Program did not follow up the established procedures for hiring of personnel. Effects: Condition may result in noncompliance with the requirements of record retention and with internal controls as in place for COR3. Questioned Costs: None Recommendation: We recommended management to monitor the implementation of procedures in place to maintain updated employee’s personal file.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review
Finding 2019-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our payroll allowable costs testing we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. We tested 13 payroll transactions charged to CTG program and 25 payroll transactions charged to the ISD program and noted that all transactions tested did not have approved pay rates in the employee personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In cases where an employee worked a partial hour, the employees were under paid. In reviewing the pay rates for each of the employees, they appeared reasonable and consistent with similar entities across the State. Repeat finding: This is a repeat of Finding 2018-008, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan
Finding 2019-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our payroll allowable costs testing we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. We tested 13 payroll transactions charged to CTG program and 25 payroll transactions charged to the ISD program and noted that all transactions tested did not have approved pay rates in the employee personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In cases where an employee worked a partial hour, the employees were under paid. In reviewing the pay rates for each of the employees, they appeared reasonable and consistent with similar entities across the State. Repeat finding: This is a repeat of Finding 2018-008, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan
Finding 2019-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our payroll allowable costs testing we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. We tested 13 payroll transactions charged to CTG program and 25 payroll transactions charged to the ISD program and noted that all transactions tested did not have approved pay rates in the employee personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In cases where an employee worked a partial hour, the employees were under paid. In reviewing the pay rates for each of the employees, they appeared reasonable and consistent with similar entities across the State. Repeat finding: This is a repeat of Finding 2018-008, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan
Finding 2019-009 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Per 2 CFR part 200.430, personnel expenses recorded into a federal program must be based on records that accurately reflect the work performed. Hourly employees should be paid for hours worked and documented through a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Internal controls procedures should be in place to ensure that all cash disbursements and payroll transactions are adequately supported by documentation, approved with accurate account coding on the approval form, retained for support either in the vendor, employee, or program file. Condition and Context: During our payroll allowable costs testing we noted that the Community is incorrectly calculating the gross pay from the timesheets. The Community is taking the employee’s hourly rate multiplied by the hours worked with minutes calculated using 100 minutes per hour instead of 60 minutes. This results in an underpayment on any partial hour worked. We tested 13 payroll transactions charged to CTG program and 25 payroll transactions charged to the ISD program and noted that all transactions tested did not have approved pay rates in the employee personnel files. Cause: Lack of internal controls over payroll transactions. Effect: Lack of internal control over payroll transactions poses the risk that the Community will expend federal funds for non-grant purposes. Questioned costs: None noted. In cases where an employee worked a partial hour, the employees were under paid. In reviewing the pay rates for each of the employees, they appeared reasonable and consistent with similar entities across the State. Repeat finding: This is a repeat of Finding 2018-008, therefore, we believe this to be a systemic issue. Recommendation: We recommend that management implement policies and procedures to ensure that all paychecks are supported by an approved pay rate, hours worked agree to the hours paid and are accurately calculated. Management Response: Management agrees with this finding, see Corrective Action Plan