Finding Text
Federal Agency U.S Department of Health and Human Services Assistance Listing Numbers 93.884 Primary Care Training and Enhancement and 93.732 Integrated Substance Use Disorder Training Program Award Numbers D58HP39725, T34HP42128, T62HP45934, T62HP49309 Criteria In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430 Compensation – personal services), payroll expenses must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. [X] Compliance Finding [X ] Significant Deficiency [ ] Material Weakness Condition During fiscal year 2024, the Organization charged payroll costs to Federal programs based on predetermined budgeted percentages rather than actual time and effort of employees working across multiple programs. Cause The Organization did not have a process or controls in place to track and document the time and effort employees spent toward each federal award. Effect Noncompliance with documentation of personnel expense standards; improper allocation of salary and fringe benefits. Questioned Costs Indeterminable. Recommendation We recommend the Organization enhance its timekeeping processes to ensure payroll charges accurately reflect actual work performed on Federal awards. If budget estimates continue to be used, they should be reconciled regularly against actual effort. Alternatively, the Organization could implement an after-the-fact certification system to document that salaries charged to Federal programs are reasonable and consistent with actual work performed. Views of responsible officials and planned corrective action Cahaba Medical Care will implement a formal process to document time and effort for personnel, subject to the level of effort requirements. This process will require time and effort for personnel to attest to the amount of time spent on a grant monthly. These personnel have been informed of the proposed process and trained to promote consistent and accurate reporting relative to federal standards.