Finding 1207132 (2025-002)

Finding Number: 2025-002 Federal Program: Ending the HIV Epidemic: A Plan for America Federal Award Identification Number: UT833926 Assistance Listing Number (ALN): 93.686 Federal Awarding Agency: Department of Health & Human Services Compliance Requirement: Activities Allowed or Unallowed & Allowable Costs/Cost Principles Pass-through Entity: Direct Award Repeat Finding: No Prior Audit Finding Number: N/A Material Weakness – Payroll Approvals Criteria 2 CFR § 300.106 gives regulatory effect to U.S. Department of Health & Human Services for 2 CFR § 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. These controls must provide reasonable assurance that awards are managed in compliance with applicable statutes, regulations, and award terms, and should align with standards issued by the Government Accountability Office or the Committee of Sponsoring Organizations of the Treadway Commission. Additionally, 2 CFR § 200.430(g)(1)(i) requires that charges to Federal awards for salaries and wages be supported by records that accurately reflect the work performed and are backed by a system of internal controls ensuring the charges are accurate, allowable, and properly allocated. The City of Columbus’ Department of Public Health policy titled, “Staff Timekeeping for Grant Funded Positions,” Part I, requires all grant funded staff to complete timesheets reflecting total hours worked and grant-related hours. Section D, specifically, requires that timesheets must be signed by and submitted for approval on the Tuesday following the end of a pay period. Timesheets submitted for approval must be approved by either the employees’ supervisor or the director of the program by the Thursday following the end of a pay period. Condition Although the City has established policies consistent with Federal requirements, supervisory review of timesheets was not performed timely in all instances. During testing of the payroll records under AL #93.686 (Ending the HIV Epidemic: A Plan for America), none of the 40 timesheets tested were reviewed within the required timeframe referenced in the Criteria section. Cause Supervisory personnel did not consistently follow established procedures for timely review and approval of timesheets. Effect Failure to follow the established internal control policy and ensuring all timesheets are appropriately reviewed and approved by a knowledgeable supervisor, within the required timeframe referenced in the Criteria section, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. Recommendation The City should reinforce its existing policies with supervisory staff and implement additional procedures, if necessary, to ensure timesheets are reviewed and approved within the required timeframe prior to charging costs to Federal programs. Officials’ Response: Refer to the Corrective Action Plan.