Finding 1220131 (2025-005)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-06-29
Audit: 405305
Organization: Civil Air Patrol (AL)

AI Summary

  • Core Issue: Non-Federal payroll expenses were incorrectly charged to Federal funding, totaling $13,800.
  • Impacted Requirements: Compliance with 2 CFR 200.430(g)(1)(vi) regarding accurate salary records and proper allocation of payroll costs.
  • Recommended Follow-Up: Improve time allocation procedures, increase employee communication on requirements, and conduct quarterly payroll reviews by an independent party.

Finding Text

Information on the federal program: United States Airforce, Assistance listing # 12.840 Civil Air Patrol Program Criteria: 2 CFR 200.430(g)(1)(vi) states, "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on a Federal award and non-Federal award." Condition: A review of all non-Federal travel costs identified six instances in which non-Federal payroll expenses were incorrectly charged to Federal funding. Additionally, one employee hired in the fourth quarter should have received a standard non-Federal payroll allocation but did not, while another employee hired during the same period received this allocation in error. The related unallowable costs totaled $13,800. These issues were communicated to management, who plan to fully reimburse the Federal Government by June 30, 2026. Cause: Time allocation procedures were not consistently followed at the employee level. Effect: Non-Federal activities were charged to Federal funding. Repeat Finding: No Questioned Costs: None reported. Recommendation: Procedures around time allocation should be examined for potential automation based on non-Federal expenditures postings and regular communications of time allocation requirements to employees should be increased. A review of regular payroll allocations should be performed quarterly to ensure they agree to the current duties and responsibilities of employees. This review should be performed and documented by someone other than the preparer. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.

Corrective Action Plan

We concur with the finding and are implementing procedures to address all issues. The payroll allocation errors identified were caused by inconsistent application of time allocation procedures at the employee level and insufficient monitoring controls to detect misallocations in a timely manner. CAP plans to reimburse the related unallowable costs to the Federal Government by June 30, 2026. To address these issues, CAP is enhancing its internal controls over payroll allocations. CAP will conduct mandatory refresher training for applicable staff on time allocation requirements to reinforce compliance expectations. Additionally, CAP has implemented a new accounting system that will allow for the use of validation rules designed to prompt time allocations when employees charged to federal funding engage in non-federal activities. CAP will also perform periodic reviews of payroll allocations to ensure that they align with employees’ current duties and funding sources, and these reviews will be documented and performed by personnel independent of the preparer. These actions are designed to improve the accuracy and consistency of payroll allocations and ensure compliance with federal cost principles. CAP expects to fully implement these corrective actions by June 2026.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1220129 2025-003
    Material Weakness Repeat
  • 1220130 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
12.840 CIVIL AIR PATROL PROGRAM $80.38M