Finding Text
AL number: 21.027 AL title: Coronavirus State and Local Fiscal Recovery Funds Federal award identification number and year: SLFRP4542 - 2023; HS2024-1262 - 2024 Name of federal agency: U.S. Department of Treasury Name of pass-through entity: Missouri Department of Economic Development; St. Louis County Department of Human Services Repeat finding: No Criteria: Under Uniform Guidance (2 CFR §200.430), compensation for personal services charged to federal awards must be based on records that accurately reflect the work performed and must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: The Organization did not have a formalized process for the review and approval of payroll transactions, including the allocations of payroll costs to grants. Cause: The Organization did not implement sufficient internal controls over payroll processing and grant cost allocation. There is a lack of documented procedures, oversight, and personnel with the necessary expertise in federal grant compliance to ensure payroll costs are properly reviewed and allocated. Possible effect: The absence of a formal review and approval process for payroll and grant allocations increases the risk of inaccurate or unallowable costs being charged to federal awards. This could result in questioned costs, audit findings, and potential repayment of grant funds, as well as noncompliance with Uniform Guidance requirements. Questioned cost: None. Recommendation: The Organization should implement a formal payroll review and approval process that includes documented supervisory review of payroll registers and allocations. Additionally, establish a standardized methodology for allocating payroll costs to grants, supported by time and effort documentation. Assign responsibility to personnel with appropriate grant management expertise to oversee compliance with federal requirements. Maintain evidence of all reviews and approvals to support audit readiness. Views of responsible officials: Management agrees with this finding. See the Corrective Action Plan.