Finding Text
Federal Program: ALN 93.575 Child Care and Development Block Grant (CCDBG) Category: Compliance Compliance requirements: Allowable costs Record retention Condition: The BGCPR did not maintain sufficient documentation to demonstrate compliance with employee background check requirements. Criteria: Pursuant to 2 CFR §200.430(a)(2), compensation costs are allowable when appointments are made in accordance with the recipient's written policies and procedures. Further, 2 CFR §200.303(a) requires recipients to establish and maintain effective internal controls to ensure compliance with applicable requirements. Additionally, 2 CFR §200.403(g) requires costs charged to Federal awards to be adequately documented. Moreover, pursuant to 2 CFR §200.334, recipients and subrecipients must retain all Federal award records, including financial records, supporting documentation, and statistical records, for a minimum of three years from the date of submission of the final financial report. If litigation, claims, or audit findings are initiated before the expiration of the retention period, the records must be retained until all such matters are resolved and final action has been taken. Per the BGCPR Human Resources Policies and Procedures Manual, specifically the Required Certifications and Background Check Policy, all employees and leaders must maintain current required certifications and documentation, including Criminal Record Certificate, Health Certificate, Law 300 Certificate, Educational Credentials, and Fingerprint Verification, and must successfully complete applicable background checks before perform their duties. Failure to comply with these requirements may result in restrictions from performing job responsibilities and may affect continued employment. Context: We found that two (2) of the four (4) sample employees lacked documentation, evidencing compliance with BGCPR's required background check procedures. Cause: For two (2) payroll-related items, the personnel files did not contain evidence demonstrating that required background checks had been completed in accordance with the BGCPR's hiring policies. For one employee, the background check was performed after the employee's recruitment date. For the second employee, the required background check documentation was not available in the personnel file at the time of the audit. Although management subsequently provided the documentation after the exception was identified, the evidence indicated that the background check report was printed in July 2026. Accordingly, the personnel files did not contain sufficient documentation to support compliance with the BGCPR's background check requirements during the audited period. Questioned cost: Amount is below the threshold to be considered a questioned cost. Effect or potential effect: As a result, BGCPR could not demonstrate that the employees were hired in accordance with established hiring requirements or that compensation costs charged to the Federal award were supported by adequate documentation. Recommendation: Ensure personnel records are complete, accurate, and maintained in accordance with established policies and procedures Views of officials responsible: BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Anticipated completion date: September 30, 2026