Finding Text
45 CFR part 75 gives regulatory effect to the Department of Health and Human Services for 2 CFR sections 200.420 through 200.476. These sections provide the principles to be applied in establishing the allowability of certain items of cost. Section B2.4 of the Ohio Department of Health (ODH) Grants Administration Policy and Procedures (OGAPP) Manual states compensation must follow the Ohio Department of Administrative Services regulations and meet federal merit system or other requirements, where applicable. Federal guidelines require subrecipients to maintain Time and Activity or Time and Effort reporting to verify time worked for all employees who are charged less than 100% to a specific funding source. The Health District utilized its own employees for the development and implementation of the COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases subgrant. These employees performed work for multiple grants and/or general business throughout the period. Employees maintained timesheets, which documented the time, date and activities they worked on; however, this documentation was not in agreement with the actual payroll expense charged to the federal grant. We identified 2 out of 3 employees selected for testing had actual and projected payroll costs charged to the federal program totaling $1,385 and $3,436, respectively, that was not supported by Time and Activity or Time and Effort documentation. Additionally, 1 out of 3 employees selected for testing was charged less to the grant than was supported by their Time and Activity and Time and Effort documentation. These errors were due to a failure in the Health District’s internal control to ensure supporting Time and Activity and Time and Effort documentation was in agreement with actual costs charged to the federal grant. Failure to have adequate controls in place to complete accurate time and effort documentation and ensuring the documentation is in agreement with costs charged to federal grants could result in the Health District not meeting federal compliance requirements and result in questioned costs for federal programs. The Health District should implement and have controls in place to ensure salaries and wages are adequately documented and properly charged to the respective federal programs.