Finding Text
_ Federal Program Information: Funding Agency: U.S. Department of Health and Human Services Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Award Number: 5H79SM087568 Award Period: 12/31/2022 – 09/29/2026 Criteria: Per 2 CFR 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the award. Per 2 CFR 200.430(g), charges for salaries and wages must be based on records that accurately reflect the work performed. Such records must be supported by a system of internal control that provides reasonable assurance the charges are accurate, allowable, properly allocated and be incorporated into official records. Budget estimates alone do not qualify as support for charges to federal awards; where budget estimates are used for interim charging purposes. The system must produce reasonably accurate results and significant changes in work distribution must be identified and entered into the records in a timely manner. Condition: During our testwork, we noted one payroll transaction of the forty two disbursements tested where the individual performed multiple cost objectives that are not exclusively attributable to the SAMHSA award. The time charged to the SAMHSA award was based on a budgeted allocation percentage rather than a record reflecting actual effort performed on the award. No follow up certification or reconciliation of actual to budgeted effort was identified. Cause: UVNR does not have a reporting system that captures actual activity for employees who work across multiple functions or cost objectives. Effect: UVNR charged labor costs for at least one position that are not adequately supported under 2 CFR 200.430, creating risk that the amount charged to the SAMHSA award for that position's time does not reasonably reflect actual effort on the program. Recommendation: UVNR should Implement a time-and-effort reporting system compliant with Uniform Guidance for any employee whose duties are not funded 100% by a single cost objective. At minimum, this should include periodic personnel activity reports or equivalent documentation reflecting actual work performed, reviewed and approved by an appropriate official, with budgeted estimates trued up to actual activity. Management Response: Management agrees with the finding and recognizes the importance of maintaining accurate time-and-effort documentation to support personnel costs allocated across multiple programs and funding sources in compliance with Uniform Guidance. During 2026, UVNR has begun strengthening its timekeeping procedures by adding program-specific account codes to its existing Timesheets.com software, which serves as UVNR's primary time-and-effort reporting system. These codes allow employees to record actual hours worked by program or cost objective when checking in and out, providing a more accurate basis for allocating personnel expenses across funding sources. In addition, UVNR is utilizing Airtable as a supplemental tool to document and review employee work performance and program-level activities. These records provide additional supporting documentation of work performed under each program and are reviewed during monthly supervision meetings to assess alignment between employees' reported activities, assigned responsibilities, and time allocations. UVNR will further formalize its procedures to require documented supervisory review and approval of timesheets. Management will regularly reconcile actual hours recorded in Timesheets.com against payroll distributions and funding allocations, with Airtable records serving as supplementary documentation to support verification of work performed. Any discrepancies between budgeted personnel allocations and actual time worked will be reviewed, documented, and adjusted accordingly. Management will continue monitoring compliance with these procedures and retaining supporting documentation for personnel expenses charged to federal awards.