Finding Text
Criteria: Title 2, Subtitle A, Chapter 200, Subpart E, § 200.430 of the Code of Federal Regulations states that “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 that provides reasonable assurance that the charges are accurate, allowable and properly allocated” and “(vii) Budget estimated (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed;” and “(C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable and properly allocated.”
Condition: Testing over Assistance Listing #21.027 - Coronavirus State and Local Fiscal Recovery Funds indicated that salaries charged to that Federal award were based on budgeted amount. There was no documentation of the required periodic after-the-fact review of the budgeted amounts applied to ALN 21.027 that management was able to provide during the audit process.
Cause: Management was unaware that all salary and benefits charged to a Federal award must be supported by records of actual time incurred on the program. Budgeted or reasonable estimates are not sufficient. Additionally, the size of the Federal award does not impact this requirement.
Context and Perspective: This is the first year in which ALN #21.027 was a major program and required an audit. Management had implemented proper time reporting for its Head Start program, which is normally audited as a major program, but had not considered this requirement for other Federal awards.
Questioned Costs: We selected vouchers for three months and tested eighty-three salaries and wages charged to grants that were part of the ALN #21.027 program. The amount charged to ALN#21.027 for these amounts was $125,208.35 and of that amount $30,300.18 was for employees that were not 100% charged to the related grant, which would necessitate requirement for periodic after-the-fact reviews of interim charges made to a Federal award. Total salaries and wages charged to grants associated with ALN #21.027 for the year ended June 30, 2024, included with expenditures on the Schedule of Expenditures of Federal Awards were $498,984.
Effect: Salary and benefits charged to ALN #21.027 lack proper documentation, which could result in certain costs charged to related awards being disallowed.
Identification as a Repeat Finding: This finding was not a repeat finding from prior audits.
Recommendation: We recommend that Gads Hill Center management establish a formal procedure to perform periodic after-the-fact reviews of interim charges based on budget estimates made to federal awards for all federal and state funded grant programs. Such reviews should be conducted for employees with time charged to multiple federal awards, and charges should be adjusted to reflect the actual time spent, based on the review findings. One way to achieve this is to require Personnel Activity Reports or similar documentation that clearly documents employee time incurred by program for the pay period or month for employees that work on multiple grants.
Views of Responsible Officials and Planned Corrective Actions: Upon reviewing the audit finding, Gads Hill Center (GHC) acknowledges the importance of maintaining accurate and compliant documentation for personal services charged to federal and non-federal awards. To strengthen internal controls and ensure proper time reporting, GHC has implemented enhanced procedures to align with federal requirements. These measures are designed to ensure that all salaries allocated to federal and non-federal awards are appropriately documented and substantiated based on actual work performed.
In response to this finding, Gads Hill Center has immediately implemented a structured procedure to ensure compliance with federal regulations regarding time and effort reporting. Effective February 2025, the following corrective actions have been established:
• Monthly After-the-Fact Time Reporting: Employees whose salaries are allocated to federal and non-federal awards must complete monthly time reports that accurately reflect the actual time worked on each funding source.
• Review Process: These time reports are reviewed and signed by both the employee and their direct supervisor to confirm accuracy and compliance with the documented allocations and make any necessary adjustments.
• Internal Monitoring and Compliance: GHC’s finance and program leadership teams will conduct periodic reviews to ensure adherence to this procedure and make any necessary refinements to maintain compliance with federal guidelines.
By implementing these enhanced controls, Gads Hill Center is committed to ensuring accurate documentation of personal services and maintaining compliance with all federal funding requirements.