Finding Text
Allowable Costs - Payroll Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name / Assistance Listing Number / Pass-Through Agency(ies) / Pass-Through Number(s): • Block Grants for Prevention and Treatment of Substance Abuse, 93.959 o Passed through the State of Connecticut, Department of Mental Health and Addiction Services, 24MHA1009 o Passed through the Commonwealth of Pennsylvania, Department of Drug and Alcohol Programs, 4100089071 o Passed through the State of Louisiana, Department of Health, 2000758195 o Passed through the State of Oklahoma, Department of Mental Health and Substance Abuse Services, B08TI083962 & B08TI084602 • COVID-19 - Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 o Passed through the State of California, Department of Health Care Services, 21-10299 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200.430 (g) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, Compensation – Personal Services requires compliance with standards for documentation of personnel expenses which include the following: “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;” Shatterproof should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: Monthly certifications of time allocations for employees terminated during 2024 were not performed. One instance was noted where the pay rate utilized did not agree to the HRIS system but in all other instances these rates agreed. Evidence supporting the approval of the pay rates in the HRIS system could not be provided. Questioned costs: Total questioned costs are $37,125 and are shown by program below: • 93.959 $7,168 State of Connecticut, Department of Mental Health and Addiction Services $11,001 Commonwealth of Pennsylvania, Department of Drug and Alcohol Programs $3,532 State of Louisiana, Department of Health $903 State of Oklahoma, Department of Mental Health and Substance Abuse Services • 93.243 $14,521 State of California, Department of Health Care Services Context: During our testing we identified 6 terminated employees whose time allocations were not documented through monthly certifications. We were able to substantiate through position descriptions and acceptance letters that two of these employees were fully chargeable to the grant and were not included in the questioned costs. Additionally we identified one employee in our testing whose pay rate utilized did not agree to the HRIS system, however, the difference was trivial and not included in the accumulation of questioned costs. Cause: Internal controls to certify time allocations by employees and their supervisors were put into place during 2024. Monthly certifications were prepared retroactive to January 2024, however certifications could not be completed for employees who were no longer employed by Shatterproof. Additionally, pay rates from the HRIS system were noted to be used in all but one instance, however, documentation of their approval was not retained. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance and questioned costs. Repeat Finding: The finding is a modified repeat of findings in the immediately prior year. Prior year finding numbers were 2023-004 and 2023-005. Recommendation: We recommend Shatterproof ensure monthly certifications of time allocations by employees and their supervisors are performed and documented on a consistent basis. In addition, we recommend Shatterproof retain approval of the payrates entered into the HRIS and used to pay employees and ensure controls exist to ensure the proper rates are used. Views of responsible officials: There is no disagreement with the audit finding.