Finding Text
2 C.F.R. ? 2400.101 provides that unless excepted under 24 CFR chapters I through IX, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth in 2 CFR part 200, shall apply to Federal Awards made by the Department of Housing and Urban Development to non-Federal entities. 2 C.F.R. ? 200.430(a)(1) states, in part, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. In addition, 2 C.F.R. ? 200.430(i)(1) states, in part, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; be incorporated into the official records of the non-Federal entity; and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. 2 C.F.R. ? 200.430(i)(1)(viii) further states that budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the subsequent provisions are met. Due to a lack of internal controls over federal compensation costs, Erie County General Health District ultimately paid employee wages based on pre-determined budget percentages rather than actual time worked for the Assistance Listing Number #14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing federal grant program. This error resulted in $810 in salary payments being incorrectly charged to the program. Failure to have the proper controls in place to ensure the accuracy of reported payroll costs could result in the Department of Housing and Urban Development taking action against the District for failure to comply with programmatic requirements. The District should implement and have controls in place to ensure salaries and wages are properly charged to federal programs.