Finding 23879 (2022-004)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2022-11-21

AI Summary

  • Core Issue: The Association failed to provide adequate documentation for employee time allocation and did not accurately capture all program charges in its financial management system.
  • Impacted Requirements: Noncompliance with Sections 200.403(g) and 200.302 of Title 2 U.S. Code of Federal Regulations, risking funding loss and ineffective internal controls.
  • Recommended Follow-Up: Implement policies and procedures to ensure proper documentation and compliance with federal regulations to avoid future issues.

Finding Text

Finding 2022-004 Federal Programs: Assistance Listing Number: 93.470, Alzheimer?s Disease Program Initiative Criteria: Section 200.403(g) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, requires that costs be adequately documented. In addition, Section 200.302 requires that the financial management system of each non-Federal entity must provide for an identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received; an accurate, current, and complete disclosure of the financial results of each Federal award or program; and a comparison of expenditures with budget amounts for each Federal award. Condition: During our testing of internal controls associated with the Alzheimer?s Program, and the Association was not able to provide evidence for the time allocation associated with an employee whose salary was allocated to the program. In addition, for the Alzheimer?s Program, management provided an excel spreadsheet to support the charges that were made to the program rather than reporting from their financial management system that is compliant with Section 200.302. We acknowledge that the Association did track Alzheimer?s program expenditures within a cost center, however, not all of the charges made to the program were properly captured within the cost center. Cause: Policies and procedures were not implemented to ensure that supporting documentation was maintained to evidence that costs were allowable. In addition, policies and procedures were not implemented to ensure that charges made to federal programs were properly captured in the financial management system as required. Effect: An ineffective internal control system related to support and approval of costs to ensure allowability can lead to noncompliance with laws and regulations and possible loss of funding. In addition, an ineffective financial management system, could lead to noncompliance with laws and regulations and possible loss of funding. Specifically, it could lead to an incorrect identification of costs charged to a federal program and an inability to substantiate that double-charging did not occur. Questioned Cost: Could not be determined. Context: A total of 40 payroll and 40 non payroll transactions, associated with the Association?s major programs, were selected from a sample of charges made to each respective program. Of this sample, 20 payroll and 20 non payroll transactions associated with the Alzheimer?s Program were selected for testing. During our testing of internal controls, in 20 out of 20 payroll transactions associated with the Alzheimer?s Program, the Association was not able to provide evidence for the time allocation associated with one employee whose salary was allocated to the program. In addition, approximately $46,000 in program charges were not properly reflected within the appropriate cost center. Recommendations: We recommend that policies and procedures be implemented to ensure compliance with sections 200.403(g) and 200.302 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, in order to ensure compliance with laws and regulations associated with Uniform Guidance. View of Responsible Officials: Management concurs with this recommendation. See page 45 for Corrective Action Plan.

Corrective Action Plan

Identifying Number: Finding 2022-004 Finding: During our testing of internal controls associated with the Alzheimer?s Program, the Association was not able to provide evidence for the time allocation associated with an employee whose salary was allocated to the program. In addition, for the Alzheimer?s Program, management provided an excel spreadsheet to support the charges that were made to the program rather than reporting from their financial management system that is compliant with Section 200.302. We acknowledge that the Association did track Alzheimer?s program expenditures within a cost center, however, not all of the charges made to the program were properly captured within the cost center. Corrective Action Taken or Planned: We assert that we exercised significant diligence and oversight over the handling of the federal dollars associated with the Alzheimer?s program funding (ALN #93.470) to ensure that such expenditures were (i) for allowable activities and consisted of allowable costs, (ii) tracked within a cost center in the organization?s general ledger and in an Excel spreadsheet that was compiled from support such as invoices and payroll records; and (iii) were not applied against other sources of funding. This was accomplished through the following: ? All invoices submitted to the Alzheimer?s cost center were required to be submitted with signature for approval by their supervisor and were complete appropriately. All expenditures were appropriately documented with necessary signatures, and were submitted for valid purposes. ? The time allocation of the identified employee was approved y the federal government through the budgeting process, and then through quarterly reports submitted through their portal. The internal Personnel Payroll Action Form was not correctly changed to reflect the appropriate allocation of the employee across programs. The employee was thus charged correctly to the federal government, and the federal government reimbursed the agency appropriately. In the future, program allocation will be reconciled in the personnel system to coincide with grant requirements. While we assert that proper oversight of this program was exercised, we understand that the auditors were not able to view the evidence of such review via sign-offs. We will update our policies and procedures to require evidence of our oversight responsibilities be required by means such as sign-offs, email approvals, etc. Further, we will work to adapt our accounting systems to be able to track activity related to federal grants within its own cost center (or sub cost center) so as to minimize the need for external management systems such as Excel spreadsheets. While expenditures against this funding were tracked within a cost center, there were other costs also included in the cost center (thus the use of the Excel spreadsheet to isolate the costs under this federal program). Going forward, a sub cost center for such funds will be utilized, if possible, to eliminate the need for a separate Excel spreadsheet. Name of contact person and title: William Bode, Controller Anticipated completion date: Immediately

Categories

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 23876 2022-002
    Material Weakness
  • 23877 2022-003
    Material Weakness
  • 23878 2022-005
    Material Weakness
  • 23880 2022-002
    Material Weakness
  • 23881 2022-002
    Material Weakness
  • 23882 2022-002
    Material Weakness
  • 23883 2022-002
    Material Weakness
  • 23884 2022-002
    Material Weakness
  • 23885 2022-002
    Material Weakness
  • 23886 2022-002
    Material Weakness
  • 23887 2022-002
    Material Weakness
  • 23888 2022-002
    Material Weakness
  • 23889 2022-002
    Material Weakness
  • 23890 2022-002
    Material Weakness
  • 23891 2022-002
    Material Weakness
  • 23892 2022-002
    Material Weakness
  • 23893 2022-002
    Material Weakness
  • 600318 2022-002
    Material Weakness
  • 600319 2022-003
    Material Weakness
  • 600320 2022-005
    Material Weakness
  • 600321 2022-004
    Significant Deficiency
  • 600322 2022-002
    Material Weakness
  • 600323 2022-002
    Material Weakness
  • 600324 2022-002
    Material Weakness
  • 600325 2022-002
    Material Weakness
  • 600326 2022-002
    Material Weakness
  • 600327 2022-002
    Material Weakness
  • 600328 2022-002
    Material Weakness
  • 600329 2022-002
    Material Weakness
  • 600330 2022-002
    Material Weakness
  • 600331 2022-002
    Material Weakness
  • 600332 2022-002
    Material Weakness
  • 600333 2022-002
    Material Weakness
  • 600334 2022-002
    Material Weakness
  • 600335 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.498 Covid 19: Provider Relief Funds and American Rescue Plan (arp) Rural Distributions $361,134
93.470 Alzheimer's Disease Program Initiative (adpi) $313,103
21.019 Covid 19: Coronavirus Relief Fund $53,256
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $34,792
14.267 Continuum of Care Program $26,131
16.575 Crime Victim Assistance $24,230
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $18,967
16.588 Violence Against Women Formula Grants $17,447
16.738 Edward Byrne Memorial Justice Assistance Grant Program $11,364