Finding 1239601 (2025-006)

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

AI Summary

  • Core Issue: AEA used budget estimates instead of actual work records to allocate payroll costs to the Federal award, violating 2 CFR 200.430.
  • Impacted Requirements: Lack of documentation means AEA cannot prove that salary charges accurately reflect employee effort on program activities.
  • Recommended Follow-Up: AEA should implement a process to regularly review and document employee activities to ensure payroll allocations are based on actual work performed.

Finding Text

Criteria: In accordance with 2 CFR 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates alone do not qualify as support for charges to Federal awards. Condition: During our testing of payroll expenditures charged to the Weatherization Assistance Program, we noted that salary and wage costs were allocated to the Federal program using budgeted allocation percentages rather than documentation that demonstrates the actual distribution of employee activities. While the employees whose salaries were charged to the program performed work supporting program operations, AEA did not maintain records sufficient to support the percentage of time charged to the Federal award based on actual work performed. As a result, management could not demonstrate that payroll costs allocated to the program reasonably reflected employee effort devoted to program activities. Cause: AEA did not maintain a documented process for periodically reviewing and supporting payroll allocations using records that reflect employees' actual activities. Instead, payroll costs were allocated based on budgeted amounts established at the beginning of the contract period. Effect: AEA cannot demonstrate that salary and wage charges allocated to the Federal award were supported by records that accurately reflect the distribution of employee activities as required by 2 CFR 200.430(i). Consequently, there is an increased risk that payroll costs charged to the Federal award may not accurately reflect the relative benefit received by the program. Questioned Costs: Undeterminable. Context: A random sampling of the federal expenditures. Repeat Finding: This finding was not corrected. See finding item 2024-005 in the prior year findings. Recommendation: We recommend that AEA establish procedures to periodically review and document employee activities to support payroll allocations charged to Federal awards. Documentation should be maintained demonstrating the basis for salary allocations and should reasonably reflect the actual work performed in support of program and non-program activities. View of Responsible Officials: Refer to management’s corrective action plan.

Corrective Action Plan

Responsible contact(s): Agnes, Controller, and Laura, CFO. Program Directors, Program Managers/Supervisors are accountable for approval of actual work performed. Participating staff: Steve is the allocation preparer; AP Staff Accountant after training; Trina for reconciliation; employees, supervisors, and payroll support. Effective Jan 2026, AEA has replaced unsupported flat budget-based salary charges with documented allocations reflecting actual work performed. During the 1st half of 2026, allocation entries were not done monthly; starting in July 2026, the allocations entries have been done monthly. 1. Document actual activity. Employees are recording actual work by award/project and administrative or other non-Federal activity for each pay period in Salesforce. Supervisors and/or Program Managers with direct knowledge review accuracy, program benefit, and grant/category coding. A Paycom (payroll platform) check register report supplies gross pay, compensated absence, and benefit records. Payroll records cover total compensation activity. 2. Reconcile before charging awards. Steve prepares the payroll-to-award allocation. Laura has been reconciling allocations against the grant budgets, and program staff has approved the expenses before invoicing. Starting Q4, 2026, Steve will reconcile allocations to payroll and the ledger, Agnes/Trina will review and post the allocation entries; and the program staff will continue to approve before billing. 3. Control fringe and exceptions. Finance will support fringe and leave treatment under a written, consistently applied method and applicable award terms; it will not use an unsupported flat fringe percentage. Supervisors will resolve missing or changed activity records promptly. Unsupported amounts will be excluded from Federal claims pending resolution, without withholding employees earned pay. 4. Train and monitor jointly. The Salesforce support team has provided training for the employees for entering and for approval. Laura has trained the Finance, and payroll support on activity documentation, allocation changes, and deadlines. Steve will retain the approved allocation with each relevant billing package. Anticipated completion: For awards ending, Sept 30, 2026, historical review will be completed by October 15, 2026. Update written method: October 30, 2026. Anticipated completion after operating-effectiveness review: January 29, 2027.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1239565 2025-006
    Material Weakness Repeat
  • 1239566 2025-007
    Material Weakness Repeat
  • 1239567 2025-008
    Material Weakness Repeat
  • 1239568 2025-009
    Material Weakness Repeat
  • 1239569 2025-006
    Material Weakness Repeat
  • 1239570 2025-007
    Material Weakness Repeat
  • 1239571 2025-008
    Material Weakness Repeat
  • 1239572 2025-009
    Material Weakness Repeat
  • 1239573 2025-006
    Material Weakness Repeat
  • 1239574 2025-007
    Material Weakness Repeat
  • 1239575 2025-008
    Material Weakness Repeat
  • 1239576 2025-009
    Material Weakness Repeat
  • 1239577 2025-006
    Material Weakness Repeat
  • 1239578 2025-007
    Material Weakness Repeat
  • 1239579 2025-008
    Material Weakness Repeat
  • 1239580 2025-009
    Material Weakness Repeat
  • 1239581 2025-006
    Material Weakness Repeat
  • 1239582 2025-007
    Material Weakness Repeat
  • 1239583 2025-008
    Material Weakness Repeat
  • 1239584 2025-009
    Material Weakness Repeat
  • 1239585 2025-006
    Material Weakness Repeat
  • 1239586 2025-007
    Material Weakness Repeat
  • 1239587 2025-008
    Material Weakness Repeat
  • 1239588 2025-009
    Material Weakness Repeat
  • 1239589 2025-006
    Material Weakness Repeat
  • 1239590 2025-007
    Material Weakness Repeat
  • 1239591 2025-008
    Material Weakness Repeat
  • 1239592 2025-009
    Material Weakness Repeat
  • 1239593 2025-006
    Material Weakness Repeat
  • 1239594 2025-007
    Material Weakness Repeat
  • 1239595 2025-008
    Material Weakness Repeat
  • 1239596 2025-009
    Material Weakness Repeat
  • 1239597 2025-006
    Material Weakness Repeat
  • 1239598 2025-007
    Material Weakness Repeat
  • 1239599 2025-008
    Material Weakness Repeat
  • 1239600 2025-009
    Material Weakness Repeat
  • 1239602 2025-007
    Material Weakness Repeat
  • 1239603 2025-008
    Material Weakness Repeat
  • 1239604 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $766,832
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $381,396