Finding Text
U.S. Department of the Treasury Finding: Salary Certifications and Allocations Reference Number: 2024-005 Program: 21.027 COVID-19 State and Local Fiscal Recovery Funds Program Identifying Number: SLFRP0139 Type of Finding: Significant Deficiency Compliance Requirement: Allowable Costs Condition: We found that during 2024 the Land Bank charged payroll expense to the SLFRF Program for the period of October 11, 2022 through December 31, 2024. The Land Bank obtained certifications from each employee to document percentage of time dedicated to the SLFRF Program during the audit in September 2025. Documentation required by the Uniform Guidance to support payroll charges to the SLFRF program was not prepared contemporaneously. Criteria: CFR § 200.430,Compensation - Personal Services, applies to the State and Local Fiscal Recovery Funds Program and requires the following: Standards for Documentation of Personnel Expenses. i. Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: a. Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b. Be incorporated into the official records of the recipient or subrecipient; c. Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); d. Encompass federally-assisted, and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; e. Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and f. 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. Cause: The Land Bank did not prepare documentation (contemporaneous time sheets or time certifications) to support the allocation of payroll costs. The Land Bank did not analyze charges to other grants to determine if payroll costs were previously billed to a grant. Questioned Costs: None Effect: As a result, the Land Bank did not comply with the federal requirements for allowable costs under 2 CFR § 200.430. Recommendation: We recommend the Land Bank implement controls and policies to ensure payroll is properly documented and allocated to grant programs.