Finding Text
2024-004 – Head Start Allowable Costs - Significant Deficiency in Internal Control over Compliance Department of Health and Human Services AL # 93.600 Head Start Cluster Federal Grantor/ Pass-Through Grantor Grant Number Grant Period U.S. Department of Health and Human Services 07CH011972-03 04/01/23 – 03/31/24 U.S. Department of Health and Human Services 07CH011972-04 04/01/24 – 03/31/25 Questioned Costs: $207,765 How were questioned costs computed: Allocation of salary Condition: Young Women’s Christian Association of Metropolitan St. Louis, Inc. included an employee's salary in the indirect cost calculation that exceeded the Executive Level II rate. Repeat of prior year finding: No Criteria: Notwithstanding any other provision of law, no Federal funds may be used to pay any part of the compensation of an individual employed by a Head Start agency, if such compensation, including non-Federal funds, exceeds an amount equal to the rate payable for level II of the Executive Schedule under section 5313 of title 5. Cause: The Organization paid deferred bonuses to the employee during the year ended December 31, 2024, which lead to the employee being over the threshold. Due to turnover in key financial positions, the employee's compensation was not removed from the indirect calculation completed monthly. Effect: Because of the above conditions, compensation was charged to Head Start and Early Head Start programs that should have been excluded. Recommendation: We recommend that Young Women’s Christian Association of Metropolitan St. Louis, Inc. establish a policy to review all compensation projected for the year, including anticipated bonuses, to determine if an employee will be over the threshold for Level II of the Executive Schedule. If an employee is over that threshold, they should be excluded from any direct costs or indirect costs charged to the programs. View of Responsible Officials: Management agrees with the assessment and has committed to a corrective action plan.