Finding Text
Condition: Employees who charged 100% of their time to the grant lacked required certifications or timecards documenting that their time was spent exclusively on grant-related activities. - In several instances, no timecards were available. - In other cases, available timecards showed no evidence of review or approval. - Timecards did not indicate program activity. - Timecards lacked evidence of supervisor approval. - Employees whose time was allocated to multiple programs had no indication of how their time was allocated on the time card. We did note, however, that most allocated employees were working on multiple contracts within the same Federal program, and that costs were allocated among the programs based on the number of beds in each facility, which appears to be a reasonable methodology. - Salaried employees did not have a method for indicating time worked. Cause: The organization failed to implement adequate internal controls to ensure compliance with federal timekeeping and documentation requirements for personnel expenses. Additionally, there appears to be a lack of understanding of the documentation and certification requirements under 2 CFR Part 200, Subpart E. Possible effect: The lack of proper documentation and certification creates a risk that unallowable costs were charged to the grant. Questioned cost: Undetermined. Recommendation: Develop and implement policies and procedures to ensure that timecards and/or certifications are completed and retained for all employees who charge 100% of their time to the grant. Implement a compliant system of time and effort reporting for employees whose time is allocated across multiple activities to align with 2 CFR §200.430(g)(vi). Conduct training for all employees and supervisors on the requirements for documenting and certifying time and effort for federal grants. Perform periodic reviews of timekeeping records and compensation charges to verify compliance with federal requirements.Views of responsible officials: During this period, Hope the Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We are also partnering with our new 3rd party payroll provider to set up time allocation for salaried employees.