Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Programs: Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Refugee and Entrant Assistance Discretionary Grants Federal Assistance Listing Numbers: 93.566; 93.576 Pass-Through Entity Name: Wisconsin Department of Children and Families Pass-Through Grantor's Numbers: 7056, 7060, 7062A, 7065, 7068, 7071, 7072 This is repeat of finding 2023-002 Criteria: In accordance with 2 CFR 200.431, fringe benefits must be allocated in a manner consistent with the pattern of benefits attributable to the employees whose salaries and wages are chargeable to the program. Statement of Condition: The Organization used 32% of salaries and wages to report benefits through the year. The actual benefits recorded in the general ledger would reflect that benefits as a percentage of salaries for the Organization was 18% in fiscal year 2024. Cause: The Organization allocated benefits to federal awards based on 32% in fiscal year 2024. The Organization's internal controls over compliance of allowable costs did not ensure benefits were being charged based on actual costs. Effect: Payroll benefit percentages should be reviewed throughout the year for accuracy to ensure all grants and programs properly account for the activities of the Organization and to properly report benefit cost reports to funding sources. Context: For the year ending June 30, 2024, payroll benefits were charged based on estimated amounts. Payroll benefits submitted and reimbursed during this year were $132,096 and $70,790 for ALN 93.566 and ALN 93.576, respectively. Using the same percentage of benefits calculated from the Organization's overall benefits cost of 18%, payroll benefits were $75,354 and $40,382 for ALN 93.566 and ALN 93.576, respectively. Questioned Costs: The difference in payroll benefits between the estimated 32% and the Organization's actual payroll benefit rate of 18% was $56,742 for ALN 93.566 and $30,408 for ALN 93.576. The questioned costs were not based on a statistical sample. Recommendation: We recommend the Organization develop a review process to reconcile that benefits charges are reasonable based on the Organization's actual benefit rate. We also recommend that all calculations be reviewed by personnel other than the preparer to ensure proper accuracy and compliance. Management Response: The Organization acknowledges the finding regarding the fringe benefit allocation methodology used during fiscal year 2024. The 32% rate represented a fringe benefit package that included employer payroll taxes and other applicable employee benefit costs. Based on actual costs recorded in the general ledger, the appropriate fringe benefit percentage for fiscal year 2024 was approximately 18%. The Organiization recognizes the importance of ensuring that fringe benefit costs charged to federal awards are based on a reasonable, consistently applied, and adequately supported methodology that appropriately reflects allowable fringe benefit costs. Management has strengthened its procedures for reviewing the components and calculation of fringe benefit costs and will continue to evaluate the methodology used to allocate these costs to grants and programs to ensure that the amounts charged are appropriately supported and consistent with applicable federal award and grant requirements. Corrective actions implemented and ongoing include: • Strengthen procedures for identifying and documenting the allowable costs included in the fringe benefit calculation. • Ensure fringe benefit calculations include applicable employer payroll taxes and other allowable components of the fringe benefit package. • Review the fringe benefit methodology and supporting calculations against actual costs to determine whether the methodology reasonably reflects costs incurred. • Maintain review procedures and checks and balances over the calculation and allocation of fringe benefit costs to grants and programs. • Adjust the methodology or amounts charged when review of actual costs indicates that modification is necessary. • Utilize outside accounting expertise to provide additional review of fringe benefit calculations, methodology, and supporting documentation. • Continue working with applicable granting agencies, as appropriate, to ensure fringe benefit costs are appropriately supported and comply with applicable federal award requirements.