Finding Text
Finding - Allowable Costs/Cost Principles - Opioid Workforce Expansion Program - Professional, Assistance Listing #93.732, May 31, 2023 Award Year, Department of Health and Human Services Criteria or Specific Requirement The College must establish internal controls over the apportionment of employees’ salaries and wages which are chargeable to the sponsored agreement or other cost objective. Methods for apportioning salaries and wages must reasonably reflect the activity for which the employee is compensated and encompass both sponsored and all other activities on an integrated basis. Methods must also recognize the principal of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct and indirect cost activities must be confirmed by responsible persons with suitable means of verification that the work was performed.
These cost principles allow for tracking time to budget during the year, but further require that if this is the method utilized to apportion employees’ salary and wages to the program, that a true-up to actual be performed at year end.
Condition Found
In our sample of 40 payroll transactions (10 employees), each of the employee’s time and effort reports were apportioning their salaries based on budgeted percentages per the grant contract and not actual time incurred. It was further noted that employees are not using time sheets to track the actual time spent on this program. As a result, a detailed true-up to actual time incurred was not performed at year end.
Questioned Costs
None noted. The College’s Program Managers who oversee the grants included in this assistance listing provided evidence that they have periodic check-ins with the individuals working on the grants and that the time incurred on grant activities typically is in excess of budgeted time. Cause
The College did not have policies in place that would require that time sheets be used to track actual time incurred on the grant or that a true-up to actual be performed at year end and that such analysis be formally documented.
Identification as a Repeat Finding
Not a repeat finding.
Recommendation
Management should require that time sheets be utilized to document time spent on all programs and that those time sheets are reconciled to quarterly time and effort reports by program managers before they are submitted to finance for allocation in the general ledger and billing to the federal government. Alternatively, at a minimum, a true-up to actual should be performed at year end, with an adjustment to final billing at year end as is necessary.
Views of Responsible Officials and Corrective Action
See Corrective Action Plan.