Finding Text
Federal Agency: United States Department of Housing and Urban Development Pass-Through Entity: Texas Department of Housing and Community Affairs Assistance Listing Number: 14.231 Federal Program Name: Emergency Solutions Grants Program (“ESG”) Subrecipient Contract Number: 42246070038 Award Number: E24-DC-48-0001 Type of Finding: Allowable Costs/Cost Principles – Significant Deficiency in Internal Control over Compliance Criteria In accordance with 2 CFR §200.403 and §200.430, costs charged to federal awards must be allowable, allocable, and properly documented. Compensation for personnel services must be supported by records that accurately reflect the work performed and must be allocated to benefiting programs based on actual activity. In addition, the ESG contract requires that personnel costs charged to the grant be supported by accurate time distribution records that reflect actual time worked and allocate costs by specific program and funding source. Condition During testing of transactions charged to the ESG program, we noted that employee timesheets were not properly allocated by program. Payroll and related benefits charged to the program were not supported by documentation reflecting actual time spent on grant activities. While the Center maintains budget-based allocations in its accounting system, such allocations do not replace the requirement to allocate payroll costs based on actual time worked by program. Cause The payroll processing company used by the Center does not have the functionality to allocate employee time by program, and management did not implement compensating controls to ensure compliance with federal time-and-effort requirements. Effect As a result, payroll and related benefit costs charged to the ESG program were not properly supported or allocable in accordance with 2 CFR Part 200, resulting in questioned costs. These costs are subject to potential disallowance by the awarding agency and possible repayment from the Center. Questioned Costs and Likely Questioned Costs Based on the specific exceptions identified in our sample, known questioned costs totaled $4,662 for the period tested. Using the results of the sample and projecting the errors to the applicable population of transactions, we estimate likely questioned costs of $234,582 for the program. Recommendation We recommend that management strengthen internal controls over payroll and timekeeping allocation, including requiring detailed time tracking by program, enhanced supervisory review, and periodic internal monitoring. Management should also implement a review and approval process to ensure personnel costs charged to the program comply with contract terms and federal cost principles prior to reimbursement.