Finding Text
Federal Agency: United States Department of Agriculture Food and Nutrition Service ALN: 16.575 Crime Victim Assistance (VOCA) Pass-Through Grantor: State of Illinois, Illinois Criminal Justice Information Authority and State of Wisconsin Department of Justice Pass-Through Award Number: 2021/2022-VO-A/VO-01-18139; 2023-VO-01-18830; 218690; 218692 Pass-Through Award Period: 10/1/2023 to 9/30/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.430(g)(1)(vi) of the Uniform Guidance states that the standards for documentation of personnel expense must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity”. Condition: Management did not have sufficiently designed internal controls to ensure that approved changes in employees’ effort certifications for salaries and wages were accurately recorded and charged to the grant. Cause: The Organization has internal controls in place to ensure employees’ effort certifications are approved. However, the Organization did not have internal controls to ensure that changes in employees’ certified effort were recorded and charged to the grant. Effect or potential effect: Unallowable payroll costs may be charged to the federal program. Questioned costs: $707 – Grant 218692 Context: We tested a sample of 25 payroll expenses, which totaled $28,826, for the period January 1, 2024 through December 31, 2024 and identified 3 transactions, which totaled $5,848. These three transactions had a change in effort during the period that was not reflected in the labor distribution causing the Advocate Aurora Health, Inc. to overcharge the grant by $707. The total VOCA expenditures reported on the Schedule are $2,098,275 for the year ended December 31, 2024. Payroll costs totaled $1,690,963, representing 84% of the total VOCA expenditures. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: Management should ensure that changes in effort made as a result of effort report certifications are reflected in the general ledger. Views of responsible officials: Advocate Aurora Management will develop and implement written procedures to ensure the timely communication of discrepancies identified during the effort certification process to the Grant Accounting team for appropriate review and adjustment.