Finding Text
Information on Federal Program:United States Department of Health and Human Services Assistance Listing Number: 93.667Assistance Listing Name: Social Services Block Grant Pass-Through Awards under the Uniform Guidance Requirements:Pass-Through Entity Award Number Award Period
Ohio Department of Job and
Family Services HS157289
January 1, 2023 - December 31, 2023, and
January 1, 2024 - December 31, 2024Criteria: CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented and there must be sufficient documentation.Condition: During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Organization’s Title XX federal program. The Organization did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. The Organization inadvertently overallocated the time allocation for the program; however, total costs incurred by the Organization after exclusion of the overallocation were not in excess of the amounts funded by the program. Cause: The Organization did not have specific policies and procedures in place as to how monthly personnel costs across federal programs are to be aggregated and charged to federal programs. Effect or Potential Effect: An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards could lead to noncompliance with law and regulations and possible loss of funding for the related program. Repeat Finding: This is a repeat finding. Questioned Costs: None. Context: The Organization collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure did not exist at the time to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing. Recommendation: We recommend that the Organization continues their new policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation, thus demonstrating the level of effort under the uniform guidance. We further recommend that management continue to review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and the recommendation.