Finding 1173697 (2022-005)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2026-02-16
Audit: 387410
Organization: YWCA Tulsa, Inc. (OK)

AI Summary

  • Core Issue: Employee work hours charged to grants were based on estimates, lacking proper documentation.
  • Impacted Requirements: Noncompliance with 2 CFR200.430(i) and 2 CFR200.303(a) regarding accurate time tracking and internal controls.
  • Recommended Follow-Up: Implement stronger policies to ensure accurate documentation of employee time on grant activities.

Finding Text

Compliance: Activities Allowed or Unallowed and Allowable costs –Documentation of Personnel Expenses Assistance Listing Number and Title:93.566 Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: U.S. Department of Health and Human Services Pass through Entity: Oklahoma Department of Human Services Pass-through Entity Award Number: N/A Finding type: Material Noncompliance and Material Weakness Criteria: Per 2 CFR200.430(i), Standards for Documentation of Personnel Expenses, employee work hours should be based on records that accurately reflect the work performed. 2 CFR200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal laws, regulations, and the terms and conditions of Federal awards. Condition: During the course of audit, we noted the time charged to the grants was based on an estimate of efforts and did not have records to support actual time spent on grant activities. Cause: Documentation of actual time spent on grant was not captured and maintained. Effect: Failure to properly document the employee’s time may result in the submission of unallowable costs and activities causing noncompliance with federal grant guidelines. Recommendation: We recommend the Organization enforce policies and procedures to ensure that employee’s time to the grant is adequately supported.Questioned costs: Unknown. Management response: See corrective action plan on page 17.

Corrective Action Plan

Management's response: When the federal grant award came out at the end of December 2021, we did not get an approved budget and signed contract for work with the State until the beginning of July 2022 for work that dated back to October 1, 2021. Because of this, once we were able to begin invoicing, we utilized percentage allocations for employee's t ime, knowing that the majority of the employees had been doing work tied to the grant were allocated 100% to the grant and that significant time had been going to building up for the grant. However, it was not possible to go back and get time sheets that were tied to the grant for the majority of 2022 because we simply didn't have a contract in place yet. At the end of 2022, we began to utilize a more structured process for tracking allocations, requiring leadership to review their team member's allocations to grants on a quarterly basis and submit those to our Finance, HR, and Grants Compliance team to review. Because this didn't happen early enough in 2022, we did not have enough backup documentation to support the allocations based on what the audit requested. Views of Responsible Officials and Corrective Action : In 2023, we continued our structured process of time allocation reviews and quarterly approvals by leadership, HR, and Finance, and then in 2024, we launched our fi rst ever time study to also review and ensure time allocations were corresponding correctly with the time being spent on the grants. Name of Contact Person: Name:Julie Davis Title Chief Executive Officer Email: juliedavis@ywcatulsa.org Phone: 918-828-2346 Projected Implementation: The implementation is complete.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

  • 1173698 2022-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $2.16M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $230,729
97.010 CITIZENSHIP EDUCATION AND TRAINING $126,986
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $107,842
21.019 COVID-19 CORONAVIRUS RELIEF FUND $49,199
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $45,802
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $39,413
93.598 SERVICES TO VICTIMS OF A SEVERE FORM OF TRAFFICKING $8,288