Item 2023‐002 Written policies, procedures, and standards of conduct COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027 U.S. Department of Treasury Grant period: Year ended September 30, 2023 Questioned Costs – $0 Condition – The City does not have all of the written policies, procedures and standards of conduct required by UG. Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐ Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management § 200.305 Payment § 200.319 Competition § 200.320 Methods of procurement to be followed § 200.430 Compensation—personal services § 200.431 Compensation—fringe benefits Cause of Condition – The City has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the City implement the required written policies and procedures. Management’s Response – Management agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.
2023-002: Allocable Costs/Cost Principles - Reporting of PTO Time. Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086680-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal controls and material noncompliance with laws and regulations Repeat Finding: No Criteria: Per 2 CFR 200.431, Leave time is an allowable cost if, among other requirements, the costs are equitably allocated to all related activities. Condition: Accrued PTO time was adjusted as of September 30, 2023, however certain employees were transferred over to the grant program that had accrued PTO as of September 30, 2022 that was not taken into account. As a result, the grant was charged PTO time for amounts that had been accrued in prior years in other programs and activities. Identification of How Likely Questioned Costs Were Computed: Based on the accrued PTO schedules as of September 30, 2023 and 2022 Known Questioned Costs: $22,971 Context: There were five employees transferred over to the new grant program, reviewed all five transferred employees PTO accrual. Cause/Effect: This was just an oversight. A schedule was prepared but did not take into account the PTO time the employees had earned prior to transfer to the new grant program. Recommendation: We recommend that the schedule be revised to take into account the PTO time employees have prior to being transferred into the grant activities. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
COVID-19 Education Stabilization Fund - Assistance Listing 84.425D and 84.425U passed through the Pennsylvania Department of Education; Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 passed through the Pennsylvania Department of Education; Grant Period - Year Ended June 30, 2023. Criteria: In accordance with Title 2 CFR Section 200.431(c) of the Uniform Guidance, fringe benefits must be allocated to federal awards and all other activities in a manner consistent with the pattern of benefits attributable to the employees whose salaries and wages are chargeable to such federal awards and other activities. Condition: Benefits charged to federal programs included Public School Employees’ Retirement System (PSERS) employer contribution expenditures that were reimbursed by a state subsidy. Cause: The system generated payroll report that identifies federally funded staff did not properly reduce federal allocations for amounts reimbursed by the state subsidy. Effect: Failure to properly deduct the PSERS reimbursement portion allocated to federal awards is a duplication of benefits which can result in a loss of funding. Questioned Costs: Total known questioned costs of $72,697 as indicated below: • COVID-19 Education Stabilization Fund - Assistance Listing 84.425D - $8,294 • COVID-19 Education Stabilization Fund - Assistance Listing 84.425U - $34,485 • Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 - $29,918 Perspective Information: Total PSERS employer contribution expenditures charged to these federal awards were $144,098. The state subsidy reimbursed the District for approximately 50 percent of these expenditures for a total of $72,697. Identification of Repeat Findings: Not applicable. Recommendation: The District should ensure that PSERS employer contribution expenditures charged to federal awards are reduced for amounts reimbursed by other funding sources. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See District’s corrective action plan.
COVID-19 Education Stabilization Fund - Assistance Listing 84.425D and 84.425U passed through the Pennsylvania Department of Education; Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 passed through the Pennsylvania Department of Education; Grant Period - Year Ended June 30, 2023. Criteria: In accordance with Title 2 CFR Section 200.431(c) of the Uniform Guidance, fringe benefits must be allocated to federal awards and all other activities in a manner consistent with the pattern of benefits attributable to the employees whose salaries and wages are chargeable to such federal awards and other activities. Condition: Benefits charged to federal programs included Public School Employees’ Retirement System (PSERS) employer contribution expenditures that were reimbursed by a state subsidy. Cause: The system generated payroll report that identifies federally funded staff did not properly reduce federal allocations for amounts reimbursed by the state subsidy. Effect: Failure to properly deduct the PSERS reimbursement portion allocated to federal awards is a duplication of benefits which can result in a loss of funding. Questioned Costs: Total known questioned costs of $72,697 as indicated below: • COVID-19 Education Stabilization Fund - Assistance Listing 84.425D - $8,294 • COVID-19 Education Stabilization Fund - Assistance Listing 84.425U - $34,485 • Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 - $29,918 Perspective Information: Total PSERS employer contribution expenditures charged to these federal awards were $144,098. The state subsidy reimbursed the District for approximately 50 percent of these expenditures for a total of $72,697. Identification of Repeat Findings: Not applicable. Recommendation: The District should ensure that PSERS employer contribution expenditures charged to federal awards are reduced for amounts reimbursed by other funding sources. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See District’s corrective action plan.
COVID-19 Education Stabilization Fund - Assistance Listing 84.425D and 84.425U passed through the Pennsylvania Department of Education; Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 passed through the Pennsylvania Department of Education; Grant Period - Year Ended June 30, 2023. Criteria: In accordance with Title 2 CFR Section 200.431(c) of the Uniform Guidance, fringe benefits must be allocated to federal awards and all other activities in a manner consistent with the pattern of benefits attributable to the employees whose salaries and wages are chargeable to such federal awards and other activities. Condition: Benefits charged to federal programs included Public School Employees’ Retirement System (PSERS) employer contribution expenditures that were reimbursed by a state subsidy. Cause: The system generated payroll report that identifies federally funded staff did not properly reduce federal allocations for amounts reimbursed by the state subsidy. Effect: Failure to properly deduct the PSERS reimbursement portion allocated to federal awards is a duplication of benefits which can result in a loss of funding. Questioned Costs: Total known questioned costs of $72,697 as indicated below: • COVID-19 Education Stabilization Fund - Assistance Listing 84.425D - $8,294 • COVID-19 Education Stabilization Fund - Assistance Listing 84.425U - $34,485 • Title I - Grants to Local Educational Agencies - Assistance Listing 84.010 - $29,918 Perspective Information: Total PSERS employer contribution expenditures charged to these federal awards were $144,098. The state subsidy reimbursed the District for approximately 50 percent of these expenditures for a total of $72,697. Identification of Repeat Findings: Not applicable. Recommendation: The District should ensure that PSERS employer contribution expenditures charged to federal awards are reduced for amounts reimbursed by other funding sources. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See District’s corrective action plan.