Finding 2102 (2022-002)

Material Weakness Repeat Finding
Requirement
BC
Questioned Costs
-
Year
2022
Accepted
2023-11-17
Audit: 3654
Organization: Lincoln Hall (NY)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: Lincoln Hall is not properly allocating payroll expenses to the correct cost centers, affecting financial reporting accuracy.
  • Impacted Requirements: This violates Uniform Guidance on cost allocation and financial management, leading to potential compliance issues.
  • Recommended Follow-Up: Implement monthly cost allocations in the accounting system to ensure accurate financial statements and compliance with federal requirements.

Finding Text

Allowable Costs; Cash Management – (Material Weakness) Information on Federal Program: U.S. Department of Health and Human Services ALN Number: 93.676 ALN Name: Unaccompanied Alien Children Program Contract Period: 07/01/2021 - 6/30/2022   Criteria: In accordance with the Uniform Guidance §200.405, if costs benefit multiple programs, the costs should be allocated to the programs based on the proportional benefit. Per the Uniform Guidance §200.413, direct costs are those costs that can be identified specifically or directly assigned to such activities relatively easily with a high degree of accuracy. Additionally, Uniform Guidance §200.302 states that the non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit, we noted that certain payroll expenses are not being charged directly or allocated to the correct cost center in the accounting system on a monthly basis. Questioned Costs: None noted. Context: This is a condition identified per review of Lincoln Hall’s compliance with allowable costs and cash management. Effect or Potential Effect: We were able to observe and conclude that Lincoln Hall did not have cost allocations in place to properly allocate expenses throughout the year. Repeat Finding: This is a repeated finding from prior year. See Finding No. 2021-002 on the Summary Schedule of Prior Audit Findings. Cause: The primary cause of this issue is the way in which the Paychex payroll system was set up, where bi-weekly payroll runs are not being allocated by the system itself. In January 2022, Lincoln Hall switched from Paychex to ADP which allows for employee cost centers to be mapped. While this improved the monthly allocation process, the finance team still performs manual calculations of all allocations in Excel at the end of the fiscal year to update the allocations. Certain other than personnel costs are dependent on the proper allocation of the personnel costs. Recommendation: The inability to generate financial statements that incorporate the federal and state agency mandated cost allocations prevents Lincoln Hall from presenting functionally accurate interim financial statements. We recommend that these costs be properly allocated on a monthly basis and presented as recorded within Lincoln Hall’s general ledger system. Allocating these costs regularly will allow Lincoln Hall to submit accurate and substantiated interim financial data to its funding sources. Additionally, properly tracking and allocating costs on a monthly basis will prevent a material reallocation of costs by function at year-end. Views of Responsible Officials: Lincoln Hall agrees with the finding. Lincoln Hall continues to take steps to improve this process. See Lincoln Hall’s further response to this finding as described in the accompanying management’s planned corrective actions, Appendix A.

Corrective Action Plan

For the year ended June 30, 2022 audit, the audit team noted that payroll, personnel costs, and other than personnel service expenses were not being allocated by cost center on a monthly basis. This issue resulted in errors in the amount charged to various programs resulting in the need for a material allocation adjustment. In accordance with Uniform Guidance 200.405, costs that benefit multiple programs should be allocated to the programs based on the proportional benefit. Lincoln Hall did not have the adequate cost allocation mechanisms in place to properly allocate expenses throughout the year. We have been taking several steps to address the issue with allocating costs. The Federal Award Finding and Questioned Costs Finding Number 2022-002 is a result of the initial way in which the general ledger and payroll systems were set up, requiring the majority of allocation work to be done manually in Excel. These manual allocations were done in detail after fiscal year-end to ensure our financial statements at year-end were not misstated. However, this detailed allocation work was not being done on a monthly basis. We have upgraded the Serenic Navigator accounting system two times to improve its accounting capabilities and have also implemented additional allocation processes including allocation of payroll expenses of federal awards. We currently use line-item allocations in The Serenic Navigator for direct costs that are allocated when invoices are paid. During FY 2022 we are continuing to review and revise our process in order to allocate expenses (particularly payroll costs) in the general ledger on a monthly basis for allocations in the past that were performed at the end of the fiscal year. The goal of our corrective actions is to significantly limit the material reallocation of costs by function at year-end and provide us with accurate cost allocations on a monthly basis. This will allow for more accurate reporting on a month-to-month basis and, therefore, will generate more timely and accurate financial information, thereby improving our compliance with cash management during the grant period.

Categories

Allowable Costs / Cost Principles Cash Management Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 2101 2022-001
    Material Weakness Repeat
  • 2103 2022-003
    Material Weakness Repeat
  • 2104 2022-004
    Material Weakness Repeat
  • 578543 2022-001
    Material Weakness Repeat
  • 578544 2022-002
    Material Weakness Repeat
  • 578545 2022-003
    Material Weakness Repeat
  • 578546 2022-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.676 Unaccompanied Alien Children Program $11.29M
10.555 National School Lunch Program $187,417
10.553 School Breakfast Program $88,579