Finding 1240162 (2025-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-10-07
Audit: 414730
Organization: Jewish Home Lifecare, Manhattan (NY)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: Timely personnel attestations for time and effort reporting were not consistently prepared or reviewed, leading to potential inaccuracies in salary charges to federal programs.
  • Impacted Requirements: Compliance with 2 CFR, Part 200.430(i)(1) regarding accurate and allowable salary charges based on proper internal controls.
  • Recommended Follow-Up: Implement stronger policies and controls to ensure timely recording and approval of time and effort, with documentation reviewed at least monthly.

Finding Text

Finding 2025-001: Allowable Costs/Cost Principles - Time and Effort Reporting (Material Weakness) Federal Agency: U.S. Department of Labor Program Name (ALN): WIOA Cluster (17.258, 17.259, 17.278) Federal Award Identification Number and Year: Contract# 906006 for FY2025, Contract# 2025WDC005 for FY2025 Pass-through entities: New York City Department of Youth and Community Development, Workforce Development Corporation Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget's Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: We noted that personnel attestations were not timely prepared by staff members and not timely reviewed by a supervisory official for 6 out of the 7 selected samples. Cause: Procedures and controls to ensure compliance with the requirements of the Uniform Guidance were not effective. Effect or Potential Effect: Personnel expenses may not accurately reflect the work performed and/or unallowable expenses may be charged to the federal program. Questioned Costs: N/A Context: From a population of 9, we selected 7 salary transactions charged to the federal program to test controls over compliance for allowable costs/activities allowed. Out of the 7 transactions tested, we noted 6 instances where the personnel attestations were not timely prepared by staff member and not timely reviewed by a supervisory official. Identification as a Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that management implement policies, controls, and procedures to ensure that time and effort is recorded based on actual effort and approval by appropriate individuals is documented at least monthly to comply with applicable cost principles. Responsible Official's Response: Management agrees with the finding and has implemented policies and procedures to ensure that employee time and effort charged to federally funded and other restricted programs is supported by contemporaneous documentation reflecting the actual effort performed. Employee time is recorded through the organization’s established timekeeping process and is reviewed and approved by the employee’s immediate supervisor on a payroll-period basis. This control is performed every pay period and therefore occurs more frequently than the minimum monthly review and approval standard referenced in the finding. Supervisory approval is intended to provide reasonable assurance that recorded time and effort is accurate, supported, and consistent with the employee’s actual work performed and the applicable funding requirements. Management will continue to monitor compliance with these procedures and will reinforce the requirement that time and effort records be accurately maintained and appropriately approved in accordance with organizational policies and applicable federal cost principles. The New Jewish Home will also retain the applicable timekeeping and approval documentation as evidence of the control’s operation.

Corrective Action Plan

The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2025-001 – Allowable Costs/Cost Principles – U.S. Department of Labor (Assistance Listing Number: WIOA Cluster - 17.258, 17.259, 17.278) Passed through New York City Department of Youth and Community Development (Contract# 9060060), Workforce Development Corporation (Contract# 2025WDC005) – (Material Weakness) Material Weakness Recommendation We recommend that management implement policies, controls, and procedures to ensure that time and effort is recorded based on actual effort and approval by appropriate individuals is documented at least monthly to comply with applicable cost principles. Action Taken The New Jewish Home has implemented policies and procedures to ensure that employee time and effort charged to federally funded and other restricted programs is supported by contemporaneous documentation reflecting the actual effort performed. Employee time is recorded through the organization’s established timekeeping process and is reviewed and approved by the employee’s immediate supervisor on a payroll-period basis. This control is performed every pay period and therefore occurs more frequently than the minimum monthly review and approval standard referenced in the finding. Supervisory approval is intended to provide reasonable assurance that recorded time and effort is accurate, supported, and consistent with the employee’s actual work performed and the applicable funding requirements. Management will continue to monitor compliance with these procedures and will reinforce the requirement that time and effort records be accurately maintained and appropriately approved in accordance with organizational policies and applicable federal cost principles. The New Jewish Home will also retain the applicable timekeeping and approval documentation as evidence of the control’s operation. Completion Date: October 5, 2026

Categories

Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 1240160 2025-001
    Material Weakness Repeat
  • 1240161 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.259 WIOA YOUTH ACTIVITIES $1.04M
17.258 WIOA ADULT PROGRAM $185,700
93.470 ALZHEIMER€™S DISEASE PROGRAM INITIATIVE (ADPI) $70,690
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $35,432
10.558 CHILD AND ADULT CARE FOOD PROGRAM $23,211
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $14,300
93.866 AGING RESEARCH $7,043