Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: ACL Centers for Independent Living
Assistance Listing Number: 93.432
Federal Award Identification Number and Year:
2004WAILC3 - 2021
2006WAILC3 - 2021
2104WAILCL - 2022
2106WAILCL - 2022"
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period:
2004WAILC3 - 4/1/2020-9/30/22
2006WAILC3 - 4/1/20-9/30/22
2104WAILCL - 9/30/21-9/29/23
2106WAILCL - 9/30/21-9/29/23"
Type of Finding:
Allowable Activities and Allowable Costs - Payroll Disbursements
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Per 2 CFR 200.303, non-Federal entities must “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues regulations, and the terms and conditions of the Federal award.”
Condition: Payroll allocation review is performed annually by ED, which is not timely enough to accurately reflect employee's time worked. Additionally, the allocation performed had logical errors, including one employees time missing from the allocation calculation, and using an inappropriate allocation basis.
Questioned costs: None
Context: All employees included in selection deemed to work positions that are allowable to the program, however the client allocation process unreliable for all sections tested (25).
Cause: Allocations to program based on one employee's memory (ED) for full-year organizational operations. Allocations not reviewed for accuracy by other individual.
Effect: Currently, all assigned work activities employees engage in are theoretically allowable under the program, however if an employee were to work projects that are not allowable under the Federal award, reimbursement requests could be made for unallowable costs.
Repeat Finding: No
Recommendation:
1) Have employees enter time by time period and ensure time codes reflect type of activities worked that tie to Federal program allocations.
2) Have ED review employee timesheets each pay period.
3) Review allocations by program each pay period.
4) Have second individual (contract accountant) review allocations to ensure accuracy and completeness.
Views of responsible officials: There is no disagreement with the audit finding.