FAC Explorer

Finding 1057421 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-08-12
Audit: 317091
Organization: Heartland Alliance for Human Needs & Human Rights (IL)
Auditor: Grant Thornton LLP

AI Summary

  • Core Issue: An employee received retroactive pay without proper documentation to support the allowability of payroll charges.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 200.430 regarding internal controls and allowable costs for federal awards.
  • Recommended Follow-Up: Enforce existing policies to ensure all payroll costs are reviewed and documented for compliance with federal regulations.

Finding Text

FINDING 2023-001 Internal Control over Compliance and Compliance with Allowable Costs/Cost Principles Program: Federal Agency: Department of Health and Human Services Funding Year(s): 2/1/2020 – 3/31/2023 Federal Award: 90ZU0351-03-05 AL Number: 93.676 Criteria: The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “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 establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (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; (vi) [Reserved] (vii) 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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition: During the audit, we noted an instance for which an employee was reinstated and received retroactive payment for the months of September through November 2022 for which we were not able to substantiate the allowability of the payroll charges. Cause: The Organization did not follow its policies and procedures in place to ensure compliance with the requirements allowable personnel costs. Effect: Failure to follow the Organization’s control system related to review and document payroll benefits so that only allowable costs are charged to the program can lead to noncompliance with federal statutes, regulations could lead to disallowed costs. Context: This is a condition identified based upon our review of the Organization’s compliance with specified requirements. Questioned Costs: $9,864 Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization strictly enforce its existing policies and procedures to ensure that all payroll costs including benefits charged to the federal awards are reviewed and documented for allowability.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 480973 2023-005
    Significant Deficiency Repeat
  • 480974 2023-005
    Significant Deficiency Repeat
  • 480975 2023-005
    Significant Deficiency Repeat
  • 480976 2023-005
    Significant Deficiency Repeat
  • 480977 2023-005
    Significant Deficiency Repeat
  • 480978 2023-001
    Significant Deficiency
  • 480979 2023-001
    Significant Deficiency
  • 480980 2023-002
    Significant Deficiency Repeat
  • 480981 2023-002
    Significant Deficiency Repeat
  • 480982 2023-005
    Significant Deficiency Repeat
  • 480983 2023-005
    Significant Deficiency Repeat
  • 480984 2023-003
    Significant Deficiency
  • 480985 2023-004
    Significant Deficiency
  • 480986 2023-005
    Significant Deficiency Repeat
  • 480987 2023-005
    Significant Deficiency Repeat
  • 480988 2023-005
    Significant Deficiency Repeat
  • 480989 2023-005
    Significant Deficiency Repeat
  • 1057415 2023-005
    Significant Deficiency Repeat
  • 1057416 2023-005
    Significant Deficiency Repeat
  • 1057417 2023-005
    Significant Deficiency Repeat
  • 1057418 2023-005
    Significant Deficiency Repeat
  • 1057419 2023-005
    Significant Deficiency Repeat
  • 1057420 2023-001
    Significant Deficiency
  • 1057422 2023-002
    Significant Deficiency Repeat
  • 1057423 2023-002
    Significant Deficiency Repeat
  • 1057424 2023-005
    Significant Deficiency Repeat
  • 1057425 2023-005
    Significant Deficiency Repeat
  • 1057426 2023-003
    Significant Deficiency
  • 1057427 2023-004
    Significant Deficiency
  • 1057428 2023-005
    Significant Deficiency Repeat
  • 1057429 2023-005
    Significant Deficiency Repeat
  • 1057430 2023-005
    Significant Deficiency Repeat
  • 1057431 2023-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.676 Unaccompanied Alien Children Program $5.75M
14.181 Supportive Housing for Persons with Disabilities $3.13M
98.001 Usaid Foreign Assistance for Programs Overseas $2.34M
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.71M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.51M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $797,852
14.896 Family Self-Sufficiency Program $710,086
93.011 National Organizations of State and Local Officials $596,606
84.002 Adult Education - Basic Grants to States $566,592
64.033 Va Supportive Services for Veteran Families Program $501,728
93.604 Assistance for Torture Victims $488,408
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $435,281
16.575 Crime Victim Assistance $352,619
93.567 Refugee and Entrant Assistance_voluntary Agency Programs $339,527
14.241 Housing Opportunities for Persons with Aids $280,255
10.553 School Breakfast Program $250,906
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $242,161
14.239 Home Investment Partnerships Program $220,000
14.326 Project Rental Assistance Demonstration (pra Demo) Program of Section 811 Supportive Housing for Persons with Disabilities $167,654
19.345 International Programs to Support Democracy, Human Rights and Labor $163,033
14.871 Section 8 Housing Choice Vouchers $142,030
14.195 Section 8 Housing Assistance Payments Program $136,266
19.019 International Programs to Combat Human Trafficking $134,259
97.027 Emergency Management Institute (emi)_independent Study Program $120,929
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $113,598
93.917 Hiv Care Formula Grants $106,924
93.914 Hiv Emergency Relief Project Grants $90,211
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $89,761
14.267 Continuum of Care Program $85,050
93.576 Refugee and Entrant Assistance_discretionary Grants $81,047
93.566 Refugee and Entrant Assistance_state Administered Programs $80,859
19.221 Iran Assistance Program $76,629
14.850 Public and Indian Housing $65,233
21.027 Coronavirus State and Local Fiscal Recovery Funds $61,628
19.016 Iraq Assistance Program $57,202
14.238 Shelter Plus Care $47,473
16.320 Services for Trafficking Victims $45,291
93.247 Advanced Nursing Education Grant Program $34,611
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $30,542
14.218 Community Development Block Grants/entitlement Grants $24,113
93.598 Services to Victims of A Severe Form of Trafficking $21,007
93.958 Block Grants for Community Mental Health Services $20,320
16.816 John R. Justice Prosecutors and Defenders Incentive Act $19,813
14.235 Supportive Housing Program $15,441
93.236 Grants to States to Support Oral Health Workforce Activities $13,514
19.510 U.s. Refugee Admissions Program $12,349
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $8,198