Finding Text
U.S. Department of Justice
16.726 Juvenile Mentoring Program
Grant Period: 10/1/2020-9/30/2024
Contract Number: 2020-JU-FX-0009
Criteria: Under 2 CFR Section 200.303(a) a non-Federal entity is required to establish and maintain internal
controls over compliance with Federal statutes, regulations, and the terms and conditions of the Federal
grant. In addition, under 2 CFR Section 200.430 Compensation – personal services, charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed. Budget
estimates may be used for interim accounting purposes but budget estimates alone do not qualify as
support for charges to Federal awards. The entity’s system of internal controls must include a process to
review after-the-fact interim charges made to a Federal award to budget estimates and make any necessary
adjustments such that the final amount charged to the Federal award is accurate, allowable and properly
allocated.
Condition: The Academy’s internal control processes do not include a comparison of actual time charged on
the employee’s time slip to the budget allocation charged the grant to determine if the budget estimates
reflect reasonable approximations of the activities actually performed.
Effect: Without internal controls operating effectively, it is possible that the Academy could be at risk to be
out of compliance with the applicable compliance requirements.
Cause: Additional federal and other restricted grants resulted in employee’s time being allocated across
additional funding sources. In addition, the Academy was working with the grantor on a budget adjustment.
Questioned Costs: Known questioned costs: $5,573; likely questioned costs $29,683.
Perspective: There is no observable evidence of the Academy’s review and reconciliation of time slips to
budget estimates which affects both the allowable activities and allowable costs requirements.
Repeat Finding: No
Auditor’s Recommendation: We recommend the Academy establish policies and procedures to reconcile the
percentage of hours charged on time slips to the budget estimates used to bill the Federal grantor. This
should be done in conjunction with quarterly billings (or other determined regular interval), at fiscal year
end, and at the end of the grant year (if different from the Academy’s fiscal year). Views of Responsible Officials: See Corrective Action Plan