Finding 1055736 (2023-003)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-07-24
Audit: 315826
Organization: Colorado Legal Services, INC (CO)

AI Summary

  • Core Issue: Inconsistent allocation of salaries and wages to LSC grants, violating federal regulations.
  • Impacted Requirements: Federal guidelines require salary allocations to reflect actual work performed, which was not met in several instances.
  • Recommended Follow-Up: Update the cost allocation methodology to minimize manual adjustments and enhance automation based on accurate time and effort records.

Finding Text

2023 – 003: Cost Allocation of Salaries and Wages to LSC Grants Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.706060 Federal Award Identification Number and Year: 09-706060 - 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance  Other Matters Criteria or specific requirement: Federal regulations (45 CFR 1635.4(a) and 2 CFR 200.430), state that federal award recipients must base allocations of salaries and wages costs to grants on records that accurately reflect the work performed. Condition: During our testing we noted:  Two instances of employees’ pay period salaries totaling $1,742 being allocated to a grant using a flat percentage of 10%, and  One instance of an employee’s pay period salary of $147 being allocated to two grants using a combination of their time an effort on those grants while the remaining portion of the employee’s salary was allocated to LSC and two other private grants using a base of total grant hours for the period divided by total hours coded to the Organization’s general fund. As such, the salary costs mentioned above were allocated in an inconsistent manner to other grant payroll costs and were not fully representative of the employees’ time and effort. Questioned costs: $1,742 of allocated salary expense described above, which is related to Assistance Listing Number 09.706060. Context: These three instances were noting during testing of 26 payroll and payroll-related disbursements. Cause: The Organization’s salaries and wages cost allocation methodology is primarily based on time and effort records, but it often includes manual adjustments based on review of individual time records and expense data. Therefore, the methodology is challenging to apply consistently, document contemporaneously, and apply in accordance with federal regulations. Effect: The inclusion of frequent manual adjustments in the Organization’s salaries and wages cost allocation methodology could cause costs to be allocated to grants that are not reflective of the time and effort spent on grant activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records. Views of responsible officials: There is no disagreement with the audit finding

Categories

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 479294 2023-003
    Material Weakness
  • 479295 2023-004
    Significant Deficiency
  • 479296 2023-005
    Significant Deficiency
  • 479297 2023-006
    Material Weakness
  • 479298 2023-007
    Material Weakness
  • 479299 2023-003
    Material Weakness
  • 479300 2023-004
    Significant Deficiency
  • 479301 2023-005
    Significant Deficiency
  • 479302 2023-006
    Material Weakness
  • 479303 2023-007
    Material Weakness
  • 479304 2023-003
    Material Weakness
  • 479305 2023-004
    Significant Deficiency
  • 479306 2023-005
    Significant Deficiency
  • 479307 2023-006
    Material Weakness
  • 479308 2023-007
    Material Weakness
  • 479309 2023-003
    Material Weakness
  • 479310 2023-004
    Significant Deficiency
  • 479311 2023-005
    Significant Deficiency
  • 479312 2023-006
    Material Weakness
  • 479313 2023-007
    Material Weakness
  • 479314 2023-008
    Material Weakness
  • 479315 2023-008
    Material Weakness
  • 479316 2023-008
    Material Weakness
  • 479317 2023-008
    Material Weakness
  • 479318 2023-008
    Material Weakness
  • 479319 2023-008
    Material Weakness
  • 479320 2023-008
    Material Weakness
  • 479321 2023-008
    Material Weakness
  • 479322 2023-008
    Material Weakness
  • 479323 2023-008
    Material Weakness
  • 479324 2023-008
    Material Weakness
  • 479325 2023-008
    Material Weakness
  • 479326 2023-008
    Material Weakness
  • 479327 2023-009
    Material Weakness
  • 479328 2023-010
    Significant Deficiency
  • 479329 2023-009
    Material Weakness
  • 479330 2023-010
    Significant Deficiency
  • 479331 2023-009
    Material Weakness
  • 479332 2023-010
    Significant Deficiency
  • 1055737 2023-004
    Significant Deficiency
  • 1055738 2023-005
    Significant Deficiency
  • 1055739 2023-006
    Material Weakness
  • 1055740 2023-007
    Material Weakness
  • 1055741 2023-003
    Material Weakness
  • 1055742 2023-004
    Significant Deficiency
  • 1055743 2023-005
    Significant Deficiency
  • 1055744 2023-006
    Material Weakness
  • 1055745 2023-007
    Material Weakness
  • 1055746 2023-003
    Material Weakness
  • 1055747 2023-004
    Significant Deficiency
  • 1055748 2023-005
    Significant Deficiency
  • 1055749 2023-006
    Material Weakness
  • 1055750 2023-007
    Material Weakness
  • 1055751 2023-003
    Material Weakness
  • 1055752 2023-004
    Significant Deficiency
  • 1055753 2023-005
    Significant Deficiency
  • 1055754 2023-006
    Material Weakness
  • 1055755 2023-007
    Material Weakness
  • 1055756 2023-008
    Material Weakness
  • 1055757 2023-008
    Material Weakness
  • 1055758 2023-008
    Material Weakness
  • 1055759 2023-008
    Material Weakness
  • 1055760 2023-008
    Material Weakness
  • 1055761 2023-008
    Material Weakness
  • 1055762 2023-008
    Material Weakness
  • 1055763 2023-008
    Material Weakness
  • 1055764 2023-008
    Material Weakness
  • 1055765 2023-008
    Material Weakness
  • 1055766 2023-008
    Material Weakness
  • 1055767 2023-008
    Material Weakness
  • 1055768 2023-008
    Material Weakness
  • 1055769 2023-009
    Material Weakness
  • 1055770 2023-010
    Significant Deficiency
  • 1055771 2023-009
    Material Weakness
  • 1055772 2023-010
    Significant Deficiency
  • 1055773 2023-009
    Material Weakness
  • 1055774 2023-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
09.U00 Basic Field Grant $6.00M
21.027 Eviction Legal Defense $1.06M
93.044 Special Programs for the Aging, Title Iii, Part B $695,061
21.027 Arapahoe Eviction Clinic $456,208
16.575 Civil Legal Services for Victims $454,910
16.320 Services for Victims of Human Trafficking $178,481
09.U00 Agricultural Worker Grant $162,560
09.U00 Native American Grant $144,793
21.008 Low Income Taxpayer Clinics (litc) $142,673
21.027 Eviction Diversion $114,994
09.U00 Technology Innovation Grants (tig) $71,397
16.815 Tribal Civil Legal Assistance $16,888
93.044 Supportive Services and Senior Centers $6,536