Federal Programs ALN 21.027, Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency U.S. Department of Treasury Category Internal Control over Compliance; Noncompliance; Internal Control Over Financial Reporting; Significant Deficiency Compliance Requirement Activities Allowed/Cost Principles Criteria According to CFR 200.303, management must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, CFR 200.430 Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part and that the total compensation for individual employees: • Is reasonable for the services rendered and conforms to the established written policy of the recipient or subrecipient consistently applied to both Federal and non-Federal activities;• Follows an appointment made in accordance with the recipient's or subrecipient's laws, rules, or written policies and meets the requirements of Federal statute, where applicable; and • Is determined and supported as provided in paragraph (g) of this section, when applicable which states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed including supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated Finally, Government Auditing Standards (2018 Revision), paragraph 3.81, states that management is responsible for designing, implementing, and maintaining effective internal control to achieve the entity’s objectives. According to the Department’s documented internal control procedures for payroll and recruitment, salary increases, position changes, and differentials must be supported by an approved OP-15 (Salary Change Sheet), completed and signed by the Secretary of Human Resources. Condition During our tests of payroll costs related to federal awards, we noted deviations consisting of missing required documentation. Specifically, we were unable to examine the most recent OP-15 (Salary Change Sheet) for various of the employees examined. As of January 26, 2026, the most recent OP-15 (Hoja de Cambio) forms on file were outdated. OP- 15 forms for fiscal year 2025 had not been completed, and no circular letter or other formal written communication had been issued to formally address or document the delay. Management indicated that approximately 4,000 employees were pending completion of updated OP-15 forms for inclusion in their personnel files. Cause Management indicated that the condition resulted primarily from operational constraints within the Recruitment function. Specifically, the preparation of OP-15 forms is a highly manual process, as each OP-15 must be individually prepared and customized for each employee. Unlike other personnel-related documentation that can be generated through automated queries using spreadsheet and word-processing tools, OP-15 forms do not currently benefit from an automated or mechanical system. In addition, management noted that the Recruitment Department experienced staffing shortages, including an extended period during which key personnel were required to perform both professional and administrative duties. This staffing constraint, combined with the volume of affected employees (more than 4,000), significantly limited the Department’s capacity to prepare OP-15 forms in a timely manner. Management further indicated that the absence of an updated or automated system for generating OP-15 documentation contributed to delays, as the existing manual process is time-consuming and difficult to sustain given the current workload. Effect The lack of timely preparation and retention of OP-15 documentation increases the risk that payroll expenditures charged to CSFRF and the rest of the agency are not adequately supported or authorized in accordance with internal policies and federal requirements. This condition limits the Department’s ability to demonstrate compliance with applicable laws, regulations, and grant requirements and increases the risk of errors, unauthorized or inaccurate salary payments, or challenges in substantiating payroll costs during monitoring or audit reviews. Context During our tests of payroll costs related to federal awards, we were unable to examine the most recent OP-15 (Salary Change Sheet) for 27 employees out of 40 employees selected for testing. Identification of repeat finding This is not a repeat finding from previous audits. Finding No. 2025-002 – Lack of Timely Preparation and Retention of OP-15 (Hoja de Cambio) Supporting Payroll Changes Charged to Coronavirus State Fiscal Recovery Funds – (Continued) Questioned Costs None. Although OP-15 documentation was not available, alternative audit procedures did not identify unallowable or unsupported payroll costs charged to the federal program. Recommendation We recommend that the Department implement measures to ensure timely preparation, approval, and retention of OP-15 (Hoja de Cambio) forms for all personnel actions, particularly those affecting payroll charged to federal awards. Management should evaluate opportunities to automate or streamline the OP-15 preparation process, address staffing constraints, and implement monitoring controls to prevent future documentation backlogs. Additionally, management should consider issuing formal guidance or interim documentation procedures when delays in OP-15 processing occur established to ensure compliance with internal policies and federal requirements. Views of responsible officials and planned corrective actions We agreed with the auditors’ finding and recommendation. See further details regarding this matter within the Action Plan provided on pages 36-38.