Finding Text
Criteria: Federal awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The recipient may change the staffing mix and level of involvement, within limits specified by agency policy or in the award but may be required to obtain Federal awarding agency approval of changes in key personnel and changes in the project director’s time commitment/level of participation in the project. For Federal awards, this may include not only a change in the project director but also the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director. Condition: The Organization has not established written policies and procedures regarding approval of key personnel on projects funded with Federal awards. Cause: There has been a substantial number of new hires as well as turnover of management personnel throughout various levels of the Organization, which has partially delayed the planned implementation of control activities that would provide for approval of key personnel on projects funded with Federal awards. Effect: Identified controls over the Organization’s compliance with the Uniform Guidance requirements regarding special tests and provisions related to key personnel were not properly designed and implemented. Questioned Costs: None Context: We performed sample testing of partnership intermediary agreements in effect for the period under audit, which found no instances of changes in key personnel for the Federal program for which no supporting evidence could be provided. However, the Organization has not formally established written policies to ensure compliance with the Uniform Guidance requirements, which could indicate that no corrective action has been taken on this prior year audit finding. Recommendation: The Organization should implement written policies and procedures that require retention of documentary evidence of the awarding Federal agency’s approval of any changes in identified key personnel. The Organization should also consider establishing policies that facilitate maintaining records of specific key personnel identified in each of the various partnership intermediary agreements. Views of Responsible Officials: See management’s view and corrective action plan at the end of this report.