Finding Text
2022-001 Grant Administration and Record KeepingSignificant deficiency in internal control over complianceFederal Program(s) ? 21st Century Community Learning Centers GrantFederal Agency(s) ? Department of EducationPass-Through Entity(ies) ? New York State Department of EducationFederal Assistance Listing Number(s) ? 84.287Pass-through Number(s) ? C403063/ C403077Federal Award Year ? June 30, 2022Criteria:In accordance with the grant agreement between GRYC and the New York State Education Department(NYSED) for the 21st Century Community Learning Centers Grant (?21st Century?), GRYC is requiredto administer and maintain records for the program, generate program reports, and meet annualreporting requirements as outlined in the grant agreement. Management is responsible for designing,implementing, and maintaining appropriate internal control over compliance. In conjunction with this,management needs to ensure that proper allocation methodologies are in place to ensure thatexpenditures are properly recorded to programs benefitted.Condition/context:During our audit, we detected certain deficiencies in internal control over compliance as describedbelow which are identified as a significant deficiency in internal control over compliance in an auditperformed under Uniform Guidance.Management currently allocates labor costs to the various program based upon managements estimate,utilizing internal factors such as service delivery, scheduling, job descriptions, etc. Federal guidelinesrequire employee allocations to various programs to be supported by either contemporaneous timerecords or appropriate time studies (2 weeks per quarter). While management?s estimate may be anaccurate reflection of how staff spent their time, without contemporaneous records completed by staff,management cannot be assured that the costs charged to each program are reflected of staff level ofeffort.Cause:NYSED requires that GRYC submit invoices quarterly of expenditures incurred during that periodand to date, which includes payroll expenses. GRYC relied on internal software and management?sestimates to determine how often an employee worked under said grant and how much costs shouldbe allocated.Due to the limitations of this calculation, GRYC was unable to generate sufficient payroll/ grantallocations data upon request during the audit, and as a result, there was insufficient informationavailable to audit the compliance with the program?s annual service level requirements.Effect:GRYC was unable to demonstrate that they effectively kept track of employees? payroll allocationamong grants with respect to reconciling to quarterly payroll reports. Although GRYC has beenunable to meet federal reporting guidelines, these requirements were waived by the funding sources.Auditors? Recommendation:We recommend that GRYC develops an internal schedule whereby employees? time allocationamongst various grant programs are tracked more closely. Federal guidelines require employees toallocate their time on a contemporaneous basis either throughout the year or through the use ofquarterly time study. GRYC should require such contemproneous reporting and develop procedureswhereby the percentage and salary allocation reconcile to the quarterly NYS-45?s filed with the State.GRYC should designate the responsibility to generate such reports to an employee to act as theprimary person to reconcile the two reports, and designate program leads to ensure the calculation isaccurate and consistent with time spent.Managements Response:GRYC acknowledges and agrees with the finding and is in the process of developing procedures toensure compliance with grant/contract provisions and will start implementing this recommendationfor the year ended June 30, 2024.