Finding 1229740 (2025-002)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-09-14
Audit: 410951
Organization: Scottdale Early Learning, Inc. (GA)
Auditor: SMITH+HOWARD

AI Summary

  • Core Issue: The organization failed to maintain proper documentation for allocating shared costs to federal programs, specifically the Early Head Start Program.
  • Impacted Requirements: This finding violates 2 CFR 200, which mandates that costs charged to federal awards must be well-documented and justifiable.
  • Recommended Follow-Up: Management should create and document allocation methodologies, prepare supporting schedules in real-time, and establish a review process to ensure compliance and consistency.

Finding Text

Finding 2025-002- Failure to Maintain Documentation Supporting Allocation of Shared Costs Charged to Federal Programs Federal Program: Early Head Start Program (ALN 93.600) Type of Finding:  Significant Deficiency in Internal Control Over Compliance Criteria: In accordance with 2 CFR 200, costs charged to federal awards must be supported by documentation demonstrating that the costs are reasonable, allocable, and consistently applied. Organizations should maintain documented methodologies and supporting schedules for allocating shared and indirect costs among benefiting programs. Condition: The Organization did not maintain a documented methodology or supporting schedules supporting the allocation of shared personnel, occupancy, and other indirect costs among programs benefiting from common resources. Supporting schedules and allocation calculations were prepared subsequent to audit inquiry. Effect: Without a documented allocation methodology and supporting schedules, management cannot demonstrate that costs charged to federal programs were appropriately allocated in accordance with Uniform Guidance requirements. This deficiency increases the risk that federal programs may be charged costs that are not adequately supported or allocable. Cause: The Organization lacked formal procedures requiring: 1. Development of documented allocation methodologies. 2. Preparation and retention of supporting allocation schedules. 3. Periodic review of allocation calculations. 4. Training of personnel responsible for federal program cost allocations. Recommendation: We recommend management develop and formally document methodologies for allocating shared and indirect costs among benefiting programs. Supporting schedules should be prepared contemporaneously and retained to substantiate the basis for allocations applied to federal awards. Management should implement a review process to ensure allocation methodologies remain reasonable and are consistently applied. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and plans to implement documented methodologies and maintain supporting schedules for allocating shared and indirect costs among programs. Management will establish review procedures to ensure allocations are consistently applied and adequately supported.

Corrective Action Plan

Corrective Action: Management will implement the following: • The Board of Directors will formally adopt a written Cost Allocation Plan assigning every shared cost to a defined cost pool with a stated allocation base: fringe benefits allocated on direct salaries; occupancy (by site) on measured square footage; food service on meals served; information technology on user and device counts; and administrative costs on modified total direct costs. • The square footage of the Warren Avenue and Midway facilities will be measured and documented as the basis for the occupancy allocation. • Class and location tracking will be enabled in the accounting system, and payroll department codes will be assigned to every earnings line so that salaries are charged directly to the benefiting program at each payroll rather than reallocated after the fact. • Employees whose time benefits more than one federal award will complete after-the-fact time and effort certifications, signed by the employee and supervisor and reconciled to payroll at least quarterly, in accordance with 2 CFR 200.430(i). • Allocations of pooled costs will be recorded monthly through dedicated allocation accounts that must net to zero, with the monthly allocation schedule retained as the contemporaneous supporting workpaper. • Unallowable costs, including interest, penalties, lobbying, entertainment, and bad debt, will be segregated in dedicated accounts excluded from all allocation bases. • Management will review the allocation results quarterly for reasonableness and consistency; the review will be documented and signed by the Executive Director. Responsible Officials: Dr. Leah Skinner, Executive Director, with day-to-day administration by the Finance Manager and the Organization's outside accountants. Anticipated Completion Date: Board adoption of the Cost Allocation Plan and facility measurements by October 31, 2026; class and payroll coding effective with the October 2026 accounting close; the first monthly allocation entries and retained schedules for November 2026; time and effort certifications beginning with the quarter ending December 31, 2026.

Categories

Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1229735 2025-001
    Material Weakness Repeat
  • 1229736 2025-002
    Material Weakness Repeat
  • 1229737 2025-001
    Material Weakness Repeat
  • 1229738 2025-002
    Material Weakness Repeat
  • 1229739 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 HEAD START $387,435
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $216,921
10.558 CHILD AND ADULT CARE FOOD PROGRAM $161,841
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $22,573