Finding 1154851 (2024-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2024
Accepted
2025-09-23
Audit: 367196
Organization: Hawaii Good Food Alliance (HI)
Auditor: Verity CPAS

AI Summary

  • Core Issue: The Organization lacks timesheets or records to document employee hours worked, leading to unverified labor cost allocations.
  • Impacted Requirements: This violates Title 2 CFR 200.430(i), which mandates accurate records for labor costs charged to federal awards.
  • Recommended Follow-Up: Implement a timekeeping system with detailed timesheets, supervisory approvals, and reconciliation procedures for labor charges.

Finding Text

Finding No. UG-2024-001 – Lack of Timesheets for Employees Federal Agencies, Programs, and Assistance Listing Numbers: • U.S. Department of Agriculture:  Agricultural Marketing Service: • Regional Food Business Centers (Assistance Listing No. 10.186) Criteria – Per Title 2 CFR 200.430(i), charges to federal awards for labor costs must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. • Be incorporated into the official records of the non-Federal entity. • Reasonably reflect the total activity for which the employee is compensated. • Support the distribution of employees’ labor costs among specific activities or cost objectives. • Include budget estimates only as interim accounting devices, provided that actual work performed is subsequently verified. Condition – The Organization does not maintain timesheets or other records to document hours worked or labor cost allocations. Labor charges are recorded monthly based on budgeted amounts. Cause – The Organization has not implemented a timekeeping system or alternative time documentation for its employees. Payroll costs are charged based on budgeted amounts, which are not subsequently adjusted to reflect actual activities performed. Effect – The Organization cannot substantiate labor costs or demonstrate accurate allocation of labor costs charged to the program. Questioned Costs – Unknown. Recommendation – We recommend that the Organization implement a system for tracking time and effort that meets the requirements of Title 2 CFR 200.430. This system should include: • Detailed timesheets or activity reports for employees whose labor costs are charged to federal awards. • Supervisory review and approval of time records. • Procedures for reconciling budgeted labor charges to actual time worked. Views of Responsible Official(s) and Planned Corrective Action – See Corrective Action Plan on page 36.

Corrective Action Plan

Effective January 1, 2025, employees are required to complete a monthly Personnel Activity Report (PAR) where the employees document the percentage of time they spent for each grant/program during the month with a brief description of the work performed for each project. The completed form is signed by the employee and their supervisor, then retained for our records. Effective September 1, 2025, monthly PARs will include contemporaneous certification by the employee that the distribution of hours worked is correct.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
10.186 Regional Food Business Centers $2.72M
10.175 Farmers Market and Local Food Promotion Program $261,297
10.968 Increasing Land, Capital, and Market Access Program $41,318
10.177 Regional Food System Partnerships $11,396