FAC Explorer

Finding 1156820 (2024-001)

Material Weakness Repeat Finding
Requirement
J
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369210
Organization: Women for Afghan Women, INC (NY)
Auditor: Emerging Consulting Group

AI Summary

  • Core Issue: WAW used budgeted staff time percentages instead of actual hours worked to allocate salary costs to federal awards.
  • Impacted Requirements: This practice violates federal regulations (2 CFR 200) that require salary charges to be based on actual work records.
  • Recommended Follow-Up: Ensure future salary allocations are based on actual hours worked, not estimates, to comply with federal guidelines.

Finding Text

During the review of the federal awards samples related to salaries, we noted that WAW used the same percentage of staff time allocation in the projects’ budget as the basis for the allocation of salary costs to various projects, including the federal awards. The applicable federal regulations, 2 CFR 200, require that “charges to federal awards for salaries must be based on the records that accurately reflect the work performed”, such as actual hours worked, rather than based on estimated hours from the project budget. However, WAW provided after-the-fact annual certification of time/salary charged to federal grants, which supports the hours charged to federal awards and is certified by their US Country Director.

Corrective Action Plan

We will ensure to follow recommendations and be compliant with time allocation requirements. Effective January 2025, WAW transitioned to a new HR and payroll system that addressed this finding, also incorporated periodic review and reconciliation. This change strengthens compliance with 2 CFR 200.430, which requires that charges to federal awards for salaries and wages be supported by records that accurately reflect the work performed. We also note that during 2024, while timesheet hours were not directly used for reallocating salary costs, WAW had in place a monthly reconciliation process. This included comparing monthly budgeted allocations to total actual expenses and tracking all expenditures to help ensure costs remained reasonable, allocable, and allowable.

Categories

Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
93.576 Refugee and Entrant Assistance Discretionary Grants $294,310
97.010 Citizenship Education and Training $189,571
16.889 Grants for Outreach and Services to Underserved Populations $158,614
93.496 Family Violence Prevention and Services/culturally Specific Domestic Violence and Sexual Violence Services $129,604