Finding 1222634 (2025-004)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-06-30

AI Summary

  • Core Issue: Payroll benefit charges were inconsistent with approved rates, leading to inaccuracies in federal program costs.
  • Impacted Requirements: Compliance with 2 CFR §200.430(g)(1)(i) regarding accurate and allowable salary and wage charges.
  • Recommended Follow-Up: Strengthen payroll controls, implement independent reviews of benefit rate updates, and conduct periodic monitoring of payroll calculations.

Finding Text

2025-04 Activities Allowed or Unallowed, Allowable Costs/Cost Principles - Significant Deficiency Federal agency: Department of State Assistance Listing Number: 19.015 Program: Cultural, Technical and Educational Centers Criteria: Per 2 CFR §200.430(g)(1)(i), 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: During our audit, we noted that benefit charges were not consistent with approved benefit rates. Of the forty (40) payroll samples selected for testing, there was one (1) instance in which the approved benefit rates per the employee records did not agree to the amounts allocated and charged to the federal program. Cause: During an update to benefit rates in the payroll system, the revised long-term disability rate was inadvertently entered as the life insurance rate, and the long-term disability rate was not updated. Effect: Payroll related benefit costs charged to the appropriation were not based on approved rates, resulting in an overcharge for life insurance benefits and an undercharge for long-term disability benefits. $ -- Identification as a Repeat Finding, if applicable: Not applicable. Recommendation: The Center should strengthen its controls over payroll and benefit rate updates to ensure that changes are accurately entered and applied within the payroll system. The Center should implement a review and verification process whereby all updates to benefit rates are independently reviewed and reconciled to approved rates prior to processing payroll. Additionally, the Center should perform periodic monitoring of payroll calculations and benefit allocations to confirm that amounts charged to federal programs are consistent with approved rates and supporting documentation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and the recommendation. See Part IV Corrective Action Plan.

Corrective Action Plan

View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: Problem The financial audit conducted by N&K identified that there were two (2) incorrect deduction amounts that were entered into the HRIS system, resulting in an overcharge to the employee. Upon investigation, it was determined that the HR Administrator updated the wrong benefits deduction entry, which caused an incorrect overcharge for the employee’s life insurance deduction and an incorrect undercharge to their long-term disability insurance deduction. The incorrect charges occurred over a span of 15 months to a total overage of $913.59, for which the employee was not reimbursed. Root Cause The error occurred during the organization’s benefits carrier switch from Prudential Financial to The Standard. Their existing process—where the Administrator inputs changes and the Assistant performs a post-entry review—failed to detect the error, resulting in a finding within the auditor’s report. The issue appears to stem from a combination of process and control weaknesses: • Manual data entry error by the Administrator • Ineffective secondary manual review, likely due to: o Lack of a standardized checklist or validation criteria o Insufficient sampling or inconsistent spot-check methodology • Lack a system-based validation controls within the HRIS system (e.g., thresholds, alerts) • Limited accountability clarity for final verification • Lack of periodic audits in case errors are missed Immediate actions to address the current issue and mitigate employee impact • Calculate and process reimbursement for the overcharged employee (completed) • Communicate transparently with the affected employee regarding: o Nature of the error o Correction made o Reimbursement payment • Conduct a targeted audit of recent deduction changes to identify any similar errors (completed) Corrective Action Plan (Preventive Controls) To prevent future occurrences from happening, unit will implement the following changes to its administrative procedures: 1. Standardized Data Entry Protocol The unit will utilize its HR Action Form as a standard processing mechanism for benefit deduction changes made within the HRIS, including:• Source documentation verification (e.g., enrollment forms, carrier files) • Confirmation of deduction amount and effective date This will require both the processor and the reviewer to initial and certify that the change was accurately completed, thus strengthening its review process. 2. Enhancing review procedure for multiple changes done at the same time The unit will replace its previous “spot check” review process with a structured verification process that mirrors its semi-monthly timesheet report for payroll. This new report will include: • The processor documenting all deductions or changes made • The processor including supporting documentation • The auditor completing a 100% review to confirm work accuracy and cross-verification against source documents • The Director providing a final spot-check and sign-off It is important to acknowledge that these enhanced controls may introduce some operational trade-offs. In the short term, the shift to 100% review and additional dual-verification tasks will likely increase processing time and workload redundancy for both the Administrator and Assistant. There is also a risk of workflow bottlenecks, particularly during high-volume periods such as open enrollment or payroll cutoffs. Closing The implementation of new corrective and preventive measures will establish a more disciplined and reliable control environment around the East-West Center’s benefits administration. By formalizing data entry protocols, strengthening independent review, and introducing layered validation controls, the unit can significantly reduce the likelihood of this occurrence (or other-related HRIS data entry errors) while improving overall data integrity and employee trust. The proposed changes will enhance audit readiness and operational transparency for the Human Resources team.Contact Person: Human Resources Director Anticipated Completion Date: Procedures have been implemented as of report issuance date 32

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1222632 2025-002
    Material Weakness Repeat
  • 1222633 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.015 CULTURAL, TECHNICAL AND EDUCATIONAL CENTERS $19.21M
19.011 ACADEMIC EXCHANGE PROGRAMS - SPECIAL ACADEMIC EXCHANGE PROGRAMS $615,083
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $482,417
19.009 ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS $285,353
19.040 PUBLIC DIPLOMACY PROGRAMS $147,797
15.820 NATIONAL AND REGIONAL CLIMATE ADAPTATION SCIENCE CENTERS $103,974
11.429 MARINE SANCTUARY PROGRAM $65,363
10.707 RESEARCH JOINT VENTURE AGREEMENT $63,229
11.432 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION (NOAA) COOPERATIVE INSTITUTES $40,773
43.001 SCIENCE $37,620
19.501 PUBLIC DIPLOMACY PROGRAMS FOR AFGHANISTAN AND PAKISTAN $17,693
45.163 PROMOTION OF THE HUMANITIES PROFESSIONAL DEVELOPMENT $11,686
11.433 MARINE FISHERIES INITIATIVE $2,764
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $710
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $-5,380