Finding Text
Finding 2024-002: Allocation of Payroll Costs – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance – Allowable Costs/Cost Principles Federal Program: Medicaid cluster (Assistance Listing No. 93.778) Federal Agency: U.S. Department of Health and Human Services Award Year: 2022-2023 Criteria: 2 CFR 200. 430(g)(1)(vii)(C) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition / Context: During audit procedures over expenditures of federal awards for the year ended June 30, 2025, we noted that PATH CITED grant Federal funding in the amount of $2,692,789 was not included in the SEFA for the year ended June 30, 2024. Management has restated the SEFA to include $2,692,789 PATH CITED expenditures for the year ended June 30, 2024. As a result of restating the SEFA, payroll expenditures charged to the PATH CITED program for the year ended June 30, 2024 were subsequently subjected to audit procedures. On 2 of 35 payroll related transactions for the PATH CITED program, we noted that there was not a policy or control in place to provide the following: 1) reasonable assurance that the amount allocated to the Federal award was accurate, allowable, properly supported and allocated; and 2) that the actual charges allocated to the Federal award were based on employee supervisor determination instead of supervisor approved employee time studies. Cause and Effect: At the time the PATH CITED program was implemented and expenditures were incurred during fiscal year 2023, the grant agreements and publicly available documentation from the DHCS did not identify the funding as federal pass-through assistance and did not include the related Assistance Listing Number or other federal award identification elements typically required under Uniform Guidance. Based on the information available at that time, the Organization reasonably concluded that the funding was not subject to Uniform Guidance requirements and therefore applied its standard operational allocation practices and as such, did not apply the Organization's Federal award payroll allocation policy of performing time studies. Payroll costs were allocated based on milestone progress, program involvement, and supervisor-approved amounts, which management believes reasonably reflected the work performed, but did not have a process in place to ensure that the payroll related expenditures were updated to provide reasonable assurance of activity performed and that documentation of supervisor approval was retained. Questioned costs: $0 Repeat Finding: Yes, Finding Number 2023-002. Recommendation: We recommend management strengthen existing policies and procedures and improve the effectiveness of related internal controls to ensure that reasonable assurance of activity performed are charged to the Federal award and that documentation of supervisor approval is retained. Views of Responsible Officials and Planned Corrective Action: Management acknowledges that documentation supporting payroll allocations for PATH CITED-related activities did not fully align with Uniform Guidance expectations for federal awards. However, similar to Finding 2023-001, the Organization was not aware that PATH CITED funding constituted federal assistance during FY2023 due to the absence of federal identifiers in grant documentation and related communications from DHCS. As such, payroll costs were managed under the Organization’s standard operational practices rather than federal compliance-specific requirements. The Organization applied a reasonable and consistent allocation methodology based on supervisory oversight and expected levels of effort, which management believes appropriately reflected the work performed, given the nature of the program at that time. Upon confirmation of the federal nature of the funding, management will take the following corrective actions which includes enhancing a time attestation/time studies process for personnel working on federal awards and strengthening policies requiring periodic after-the-fact review of payroll allocations and documentation retention requirements for supervisory approvals.