Finding Text
FINDING 2022-002 Identification of the Federal Program: 21st Century Community Learning Centers (Assistance Listing 84.287C), Temporary Assistance for Needy Families (Assistance Listing 93.558) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Allowable Costs/Cost Principles - According to 2 CFR ?200.430(i)(viii), 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: (A) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) significant changes in the corresponding work activity (as defined by the non-Federal entity?s written policies) are identified and entered into the records in a timely manner; and (C) the non-Federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. Condition: Records to substantiate the allocation of payroll costs to the grant were not maintained. Cause: Lack of internal controls and administrative oversight with respect to time and effort recordkeeping. Effect or Potential Effect: The Organization did not meet the standards for documentation of personnel expenses. Questioned Costs: Indeterminable. Context: Time and effort system was not implemented until after the audit year; as such, timesheets could not be provided to substantiate hours allocated to the Organization?s federal awards. Identification as a Repeat Finding: This is a repeat finding of Finding 2021-001. Recommendation: We recommend that the Organization establish policies and procedures as well as enhance its internal controls to ensure that salaries and wages charged to a federal award accurately reflect the work performed. Views of Responsible Officials: The Alliance employees will implement a policy and procedures, as well as grant requirements, to ensure that timesheets are completed and certified by both the employee and their supervisor. All Alliance employees will begin to record and submit grant time physical Timesheets. The Timesheets will be used to determine the appropriate amount of the employee?s payroll and payroll related costs that should be allocated to the grant(s) that receive the benefit of the employee?s time and effort. This finding was identified by the Alliance prior to audit when new Executive Director Awisi Bustos began her leadership at the Alliance in January of 2023. It was identified that the prior years corrective action plan was determined to be ineffective. The corrective action plan laid out here has already taken effect.