Finding 1239207 (2025-001)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to payroll documentation for the Environmental Quality Incentives Program.
  • Impacted Requirements: Federal standards require accurate records for salaries and wages, supported by a robust internal control system to ensure charges are allowable and properly allocated.
  • Recommended Follow-Up: Implement a compensating control to document formal reviews and approvals of time and effort studies, ensuring payroll costs align with approved documentation.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Environmental Quality Incentives Program Assistance Listing Number: 10.912 Federal Award Identification Number and Year: NR243A750011G009 - 2024 Award Period: 9/1/24-9/29/29 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Allowable Costs and Activities Criteria or specific requirement: Standards require that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Of the 40 payroll disbursements selected for testing, noted 15 did not have a formal review and approval documented over the payroll for time and effort documentation. Questioned costs: None Context: Of the 40 payroll disbursements selected for testing, noted 15 did not have a formal review and approval documented over the payroll for time and effort documentation. Per testing, noted no employee charges more than 100% of their time across federal funding or other funding sources. This was a finding in the prior year audit and a plan was put into place in September 2025 to address the time and effort issue but was not implemented for part of the period under audit. Cause: Due to the timing of when the formal procedures were put in place. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities. Repeat Finding: Repeat Finding 2024-002 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over time & effort studies and allocations. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over time & effort studies and allocations. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Status of corrective action: This finding recurred in 2025 due to the timing of implementation, not because the corrective actions were ineffective. The corrective actions described below were fully in place by October 2025, after the start of the January 1 to December 31, 2025 audit period, so the controls were not in operation for the full year. The controls have been in operation since implementation, and the Organization expects this finding to be resolved in the audit for the year ending December 31, 2026, which will be the first audit period in which the controls operate for the entire year. Time and effort studies: Beginning in September 2025, the Organization conducts monthly time studies by position. Management reviews and approves each time study, and the approval is documented and dated by email to the Outsourced Accountant. When actual time spent deviates from the most recent time study, payroll allocations are adjusted so that charges to each funding source reflect actual effort. Payroll allocation reconciliation (compensating control): Each month, before payroll costs are included in a claim for reimbursement, the Director of Operations or a designee independent of payroll preparation compares the payroll processed and allocated to the Environmental Quality Incentives Program award to the approved time and effort documentation by funding source. Any difference is investigated and corrected in the general ledger before the costs are claimed, so that payroll charged to the award does not exceed the effort supported. Name of the contact person responsible for corrective action: Angie Sullivan, Director of Operations Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026

Categories

Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1239208 2025-002
    Material Weakness Repeat
  • 1239209 2025-003
    Material Weakness Repeat
  • 1239210 2025-004
    Material Weakness Repeat
  • 1239211 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.912 Environmental Quality Incentives Program $725,547
10.937 Partnerships for Climate-Smart Commodities $529,243
10.311 Beginning Farmers and Ranchers Development Program $110,252
10.902 Soil and Water Conservation $80,549
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $33,807
10.164 Wholesale Farmers and Alternative Market Development $16,142