Finding 1205667 (2025-007)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-04-01
Audit: 397378
Organization: City of South Gate (CA)
Auditor: DAVIS FARR LLP

AI Summary

  • Core Issue: Payroll costs were charged to federal programs based on fixed percentages instead of actual hours worked, violating federal documentation standards.
  • Impacted Requirements: Compliance with 2 CFR 200.430(i) is at risk, as charges must reflect actual work performed and not just budget estimates.
  • Recommended Follow-Up: Implement a system to track actual hours worked by employees on each program to ensure accurate payroll documentation and compliance.

Finding Text

2025-007: Federal Awards – Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development CFDA No.: 14.218 Federal Program: Community Development Block Grants/Entitlement Grants Federal Award Year: 2025 Control Category: Allowable Costs Known Questioned Costs: $17,375 (sample) Projected Questioned Costs: $217,355 (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 the program 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 $17,375 from the sample tested and $217,355 of projected questioned costs from projections. These costs are unsupported due to inadequate time documentation, not necessarily unallowable.

Corrective Action Plan

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of distributing payroll costs using predetermined allocation percentages for employees working across multiple programs did not fully satisfy federal requirements for documenting actual time expended on CDBG-eligible activities. Management notes that the projected questioned costs of $217,355 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 isprepared to work with HUD to determine the appropriate resolution of these questioned costs. The City is implementing the following corrective actions: 1. Actual Time Reporting: Effective immediately, all employees who charge any portion of their time to federal grant programs—including CDBG—are required to document actual hours worked on each program or activity in their timesheets. Time entries must correspond to specific program activities and must be reviewed and certified by the employee's supervisor each pay period. 2. Discontinuation of Fixed Allocation Percentages: The City is eliminating the use of predetermined payroll allocation percentages as the basis for charging personnel costs to federally funded programs. Future payroll charges to federal awards will be based exclusively on actual documented hours, in compliance with 2 CFR 200.430(i). 3. Staff Training: The City will provide mandatory training to all employees who charge time to federal programs, supervisors responsible for timesheet review, and payroll staff. Training will cover the requirements of 2 CFR 200.430, the City's updated time documentation procedures, and the consequences of noncompliance.4. Quarterly Internal Compliance Reviews: Beginning in Q1 of FY 2025-26, the Accounting & Finance Division will conduct quarterly reviews of payroll charges to all federal programs to confirm that expenditures are supported by compliant time records. Results will be reported to the applicable department directors.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1205662 2025-007
    Material Weakness Repeat
  • 1205663 2025-007
    Material Weakness Repeat
  • 1205664 2025-007
    Material Weakness Repeat
  • 1205665 2025-007
    Material Weakness Repeat
  • 1205666 2025-007
    Material Weakness Repeat
  • 1205668 2025-008
    Material Weakness Repeat
  • 1205669 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $9.78M
16.922 EQUITABLE SHARING PROGRAM $1.03M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $397,032
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