Finding 1201199 (2025-008)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395860
Organization: City of South Gate (CA)
Auditor: DAVIS FARR

AI Summary

  • Core Issue: Payroll costs were charged to the federal program using fixed percentages instead of actual hours worked, leading to potential inaccuracies.
  • Impacted Requirements: This practice violates 2 CFR 200.430(i), which requires salary charges to be based on actual work records.
  • Recommended Follow-Up: Implement a system to charge time based on actual hours recorded on timesheets to ensure compliance and accuracy.

Finding Text

2025-008: Federal Awards – Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development CFDA No.: 14.871 Federal Program: Housing Choice Voucher Program Federal Award Year: 2025 Control Category: Allowable Costs Known Questioned Costs: $29,924 (sample) Projected Questioned Costs: $214,045 (projected) Condition During our testing of payroll expenditures, we noted that employee salaries and wages were charged to the federal program using predetermined allocation percentages rather than actual time recorded on employee timesheets or activity reports. Employees working on multiple programs did not maintain documentation identifying the actual hours worked on each program during the pay period. Instead, payroll costs were distributed across funding sources using fixed percentages established by management. Criteria 2 CFR 200.430(i), Standards for Documentation of Personnel Expenses, states, in part: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed…” Charges must “support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award;…” And “budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Cause The City's payroll system charges time for employees each pay period based on an allocation rather than actual hours documented on the employee’s timesheet. Effect Because payroll costs were not supported by records reflecting the actual work performed, the City cannot demonstrate that salary and wage costs charged to the federal program were accurate and properly allocable. As a result, payroll expenditures charged to theprogram may be unallowable under federal cost principles, and there is an increased risk that federal funds could be misallocated among programs. Questioned Costs There were known questioned costs in the amount of $29,924 from the sample tested and $214,045 of projected questioned costs from projections. These costs are unsupported due to inadequate time documentation, not necessarily unallowable. Recommendation We recommend that the City charge time to the program based on actual hours worked per the employees' timesheets.

Corrective Action Plan

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by records that accurately reflect actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of using predetermined allocation percentages to distribute payroll across multiple funding sources did not fully satisfy the federal standards for documenting actual time worked on HCV-eligible activities. Management notes that the projected questioned costs of $214,045 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City will coordinate with HUD to determine the appropriate resolution of these questioned costs. The corrective actions outlined in Finding 2025-007 apply equally to the HCV Program. Specifically: 1. Actual Time Reporting: All Housing Authority employees who perform HCV program activities are required to document actual hours worked per program activity on their timesheets, effective immediately. 2. Discontinuation of Fixed Allocations: Predetermined allocation percentages will no longer serve as the basis for payroll charges to the HCV Program. All charges must be supported by actual time records. 3. Timesheet System and Training: Housing Authority staff will be included in the system enhancement and training initiatives described in Finding 2025-007, with particular emphasis on documentation standards under the HCV Program's applicable requirements4. Quarterly Internal Compliance Reviews: HCV payroll charges will be included in the Accounting & Finance Division's quarterly compliance reviews, with findings reported to the City Manager and the Housing Authority Director

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1201193 2025-007
    Material Weakness Repeat
  • 1201194 2025-007
    Material Weakness Repeat
  • 1201195 2025-007
    Material Weakness Repeat
  • 1201196 2025-007
    Material Weakness Repeat
  • 1201197 2025-007
    Material Weakness Repeat
  • 1201198 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $9.78M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $6.63M
16.922 EQUITABLE SHARING PROGRAM $1.03M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $261,276
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $26,857
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $17,272
20.600 State and Community Highway Safety $15,683