Finding 1208803 (2024-007)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2026-04-24

AI Summary

  • Core Issue: Employee timecards charged to Federal grants lacked timely supervisory review and approval, leading to potential inaccuracies in payroll costs.
  • Impacted Requirements: Compliance with Uniform Guidance (2 CFR §200.303 and §200.430(i)) for effective internal controls and proper authorization of payroll costs.
  • Recommended Follow-Up: Strengthen payroll controls by ensuring timely supervisory approvals and maintaining documentation; implement regular monitoring to ensure compliance.

Finding Text

Finding 2024- 007 – Timecard Approval Controls – Payroll Charge to Federal Grant, Significant Deficiency Federal award agency: US Department of Transportation Federal Transit Administration Program name and ALN: Federal Transit Cluster ALN 20.507 Federal Transit Formula Grants, ALN 20.525 State of Good Repair Grants Federal award identification number: IL-2017-028-00, IL-2018-024-00, IL-2019-022-01, IL-2021-050-00, IL-2022-005-01, IL-2022-032-00, IL-2023-036-01, IL-2024-025-00 Federal award year: 2017, 2018, 2019, 2022, 2023, 2024 Criteria: The Uniform Guidance requires non‑Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR §200.303). In addition, payroll costs charged to Federal awards must be adequately supported and properly authorized to ensure that only allowable and accurate costs are charged (2 CFR §200.430(i)). Condition: During testing of payroll transactions charged to the Federal program, RSM identified instances in which employee timecards were not supported by evidence of timely supervisory review and approval. Specifically, for certain timecards tested, approval either could not be substantiated, occurred after fiscal year end, or lacked documentation evidencing the date of approval. Cause: Management did not consistently maintain documentation evidencing timely supervisory review and approval of employee timecards charged to Federal grants. Additionally, monitoring controls over the timeliness of timecard approvals were not sufficient to ensure compliance with established payroll control procedures. Effect or potential effect: Without timely supervisory approval of timecards, there is an increased risk that unallowable, inaccurate, or improperly allocated payroll costs could be charged to Federal awards. Questioned costs: None noted. Context: 16 control exceptions out of 60 selections. The sample was not intended to be, and was not, a statistically valid sample. Recommendation: RSM recommends that management strengthen internal controls over payroll charged to Federal grants by ensuring that all employee timecards are reviewed and approved by supervisors in a timely manner and that documentation evidencing the approval date is retained. Management should also implement periodic monitoring to verify compliance with timecard approval requirements. Views of responsible officials: Management acknowledges the finding and agrees that remediation is necessary. Management will implement the recommendations that it has defined within the corrective action plan required by Title 2 CFR 200.511(c) executed on April 16, 2026.

Corrective Action Plan

Finding Reference: 2024-007 Finding Title: Timecard Approval Controls – Payroll Charge to Federal Grant, Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Scott Dolude, Director of Payroll, Financial Affairs, (312) 322-6526 Planned Corrective Actions: 1. Timecard Approval Requirements for Federal Grants: Management will reinforce payroll control procedures to require that all employee timecards charged to Federal grants are reviewed and approved by designated supervisors in a timely manner and in accordance with established payroll deadlines. Specifically, that all required approvals must be completed prior to payroll processing and fiscal period close to ensure the allowability, accuracy, and proper allocation of costs charged to Federal awards. By June 30, 2026, management will send an email to all impact supervisory and management personnel responsible for time review and approval processes. 2. Documentation Standards and Audit Trail: Management will establish formal documentation standards to ensure that evidence of supervisory review and approval, including approval dates, is consistently retained in a secure, centralized system. These standards will support a clear and retrievable audit trail demonstrating compliance with the payroll documentation and allowability requirements of 2 CFR §200.430(i). 3. Monitoring and Compliance Oversight: Management will implement periodic monitoring procedures to assess compliance with timecard review and approval requirements. These procedures will include exception reporting, timely follow-up on identified deficiencies, and management review of monitoring results. Corrective actions will be implemented, as necessary, to address recurring or systemic issues related to untimely, incomplete, or undocumented approvals. Based on the results of monitoring processes, Director of Payroll and Timekeeping will conduct organizational, departmental, or team-based follow-up to address non-compliance or other issues. Anticipated Completion Date: 06/30/2026

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1208796 2024-006
    Material Weakness Repeat
  • 1208797 2024-007
    Material Weakness Repeat
  • 1208798 2024-008
    Material Weakness Repeat
  • 1208799 2024-006
    Material Weakness Repeat
  • 1208800 2024-007
    Material Weakness Repeat
  • 1208801 2024-008
    Material Weakness Repeat
  • 1208802 2024-006
    Material Weakness Repeat
  • 1208804 2024-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.507 COVID-19 FEDERAL TRANSIT FORMULA GRANTS $493.43M
20.525 STATE OF GOOD REPAIR GRANTS PROGRAM $146.68M
20.507 FEDERAL TRANSIT FORMULA GRANTS $71.47M
20.326 FEDERAL-STATE PARTNERSHIP FOR INTERCITY PASSENGER RAIL $4.19M
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $943,758
20.533 ALL STATIONS ACCESSIBILITY PROGRAM $916,788
20.319 HIGH-SPEED RAIL CORRIDORS AND INTERCITY PASSENGER RAIL SERVICE €“ CAPITAL ASSISTANCE GRANTS $489,160
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $324,312
20.321 RAILROAD SAFETY TECHNOLOGY GRANTS $321,300