Finding 1240642 (2025-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-10-16
Audit: 415026
Organization: JOHNSON CREEK WATERSHED COUNCIL (OR)

AI Summary

  • Core Issue: The Organization lacks an integrated financial management system, leading to difficulties in tracking and documenting payroll costs charged to Federal awards.
  • Impacted Requirements: Noncompliance with 2 CFR 200 Subpart E and 2 CFR 200.302 regarding reasonable, allocable, and adequately documented costs.
  • Recommended Follow-Up: Transition to recording payroll allocations directly in the accounting system, implement reconciliation procedures, and ensure supervisory review of timesheets.

Finding Text

2025-003 Finding – Federal Award Type: Material Weakness in Internal Control over Compliance and Noncompliance – Allowable Costs Criteria / Requirement: In accordance with 2 CFR 200 Subpart E (Uniform Guidance), costs charged to a federal award must be reasonable, allocable, consistently treated, and adequately documented. In addition, 2 CFR 200.302 requires recipients to maintain financial management systems that adequately identify and support expenditures charged to Federal awards. Condition / Context: The Organization tracked Federal expenditures charged to the grant using a workbook maintained outside of its accounting system. During testing of payroll expenditures charged to the Federal award, we noted that payroll costs charged to the grant could not be identified within the general ledger because the allocations were made only within the external workbook. Although employee timesheets documented hours worked on projects related to the grant, the Organization was unable to demonstrate a direct reconciliation between the payroll amounts charged to the Federal award and the accounting records. In addition, the timesheets provided did not contain evidence of supervisory review or approval. Cause: As a result, the Organization lacked sufficient support to demonstrate that payroll costs charged to the Federal award were properly allocated, allowable, and adequately documented. This increases the risk that payroll expenditures may be inaccurately recorded, charged to multiple Federal awards, or otherwise fail to comply with Uniform Guidance requirements. Effect: The lack of an integrated financial management system increases the risk that Federal expenditures may be inaccurately recorded, charged to multiple Federal/ non-federal awards, include unallowable costs, or otherwise fail to comply with Federal requirements. Questioned Costs: $34,623 Recommendation: We recommend the Organization discontinue reliance on external workbooks as the primary record of Federal expenditures and record payroll allocations directly within the accounting system. Management should implement procedures to reconcile payroll expenditures charged to Federal awards to the general ledger and ensure that payroll allocations are supported by approved timesheets or equivalent documentation. Additionally, management should require and document supervisory review and approval of employee timesheets to strengthen internal controls over payroll costs charged to Federal awards. Management’s Response: Management concurs with the finding and will implement effective internal controls over Allowable Costs.

Corrective Action Plan

2025-003 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance and Noncompliance – Allowable Costs Recommendation: We recommend the Organization discontinue reliance on external workbooks as the primary record of Federal expenditures and record payroll allocations directly within the accounting system. Management should implement procedures to reconcile payroll expenditures charged to Federal awards to the general ledger and ensure that payroll allocations are supported by approved timesheets or equivalent documentation. Additionally, management should require and document supervisory review and approval of employee timesheets to strengthen internal controls over payroll costs charged to Federal awards. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: In January 2026, JCWC implemented a new payroll and financial management process to strengthen the tracking, allocation, and documentation of payroll costs charged to Federal awards. Under the new process, Jitasa manages JCWC's payroll processing and payroll accounting, with QuickBooks serving as the organization's official accounting ledger. Employee time is allocated to the appropriate grant, contract, class, or organizational activity using approved timesheets. This process no longer relies on an external workbook as the primary accounting record for Federal payroll expenditures. JCWC also implemented a documented supervisory review process for payroll. Employee timesheets are reviewed for accuracy, completeness, and appropriate project allocations as part of the payroll process. Following preparation of payroll, payroll journals are reviewed and approved through DocuSign, providing a documented electronic approval trail prior to payroll processing. The Fiscal Policy Manual formalizes these procedures in Section 5.4, Payroll Authorization and Internal Controls. The policy requires employees to submit timesheets, requires management review of employee time allocations, requires payroll costs charged to grants to be supported by contemporaneous time records, and requires payroll registers to be reviewed after each payroll cycle. Payroll records are retained for a minimum of seven years. Action Plan: JCWC will continue the payroll and financial management procedures implemented in January 2026 and maintain these procedures through its formal fiscal policies and ongoing financial management practices. Jitasa will continue to manage payroll processing and payroll accounting, with JCWC management responsible for reviewing and approving payroll prior to processing and monitoring payroll allocations charged to Federal awards. Employee timesheets will continue to support payroll allocations to grants, contracts, classes, and organizational activities. Payroll journals will continue to be reviewed and approved through DocuSign, providing documented evidence of supervisory review and approval prior to payroll processing. The Finance & Grants Manager will work with Jitasa to ensure payroll expenditures charged to Federal awards are appropriately recorded and identifiable within the accounting system and reconciled to the general ledger. Name(s) of the contact people responsible for correction action: Jennifer Hamilton, Executive Director Noah Jenkins, Conservation Director Sean Connolly, Finance & Grants Manager Jitasa Plan completion date for corrective action plan: January 2026 for implementation of the new process; ongoing monitoring thereafter.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1240640 2025-001
    Material Weakness Repeat
  • 1240641 2025-002
    Material Weakness Repeat
  • 1240643 2025-004
    Material Weakness Repeat
  • 1240644 2025-005
    Material Weakness Repeat
  • 1240645 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.463 HABITAT CONSERVATION $1.43M
15.654 NATIONAL WILDLIFE REFUGE SYSTEM ENHANCEMENTS $13,737