Finding 37186 (2022-001)

Reference No: 2022-001 Assistance Listing Number: 93.982 Federal Title: COVID-19 Federal Crisis Counseling Assistance and Training Program (CCP), Regular Services Program (RSP) Federal Agency: Department of Health and Human Services Federal Award Number: 1H07SM083896-01 Program Year: June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles and Activities Allowed or Unallowed Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted that there was a lack of appropriate and sufficient review and approval of the timesheets of certain employees, a condition that may result in inaccurate payroll expenditures. Cause: The program supervisor failed to provide appropriate and timely approval of certain timesheets related to the payroll transactions of certain employees. Effect: Failure to approve the timesheets on a timely basis can result in errors in the payroll calculations which in turn can lead to the federal award being charged for costs that may not be completely accurate. Questioned Cost: None Perspective Information: From a statistically valid sample, we identified several instances in which the approved timesheets could not be provided by the Organization. These instances are audit findings and represent a systemic problem in internal controls over the timesheet approval process. Repeat Finding: Yes Recommendation: We recommend that the Organization implement appropriate and sufficient controls and enforce these controls throughout the year to ensure that the timesheets and payroll transactions are timely reviewed and approved prior to being charged to the federal award. Views of Responsible Officials: We provided a walkthrough of the updated time & attendance records approval policy to all supervisors and managers during the management team meeting on Wednesday, January 11, 2023. Additionally, we had an agency wide mandatory training which included a more thorough training and review of the policy, a review of our timecard review, approval and submission procedure and a Q&A session. We offered the training during our regularly scheduled agency-wide all staff trainings on Wednesday, January 18, 2023 and on Friday, January 20, 2023 (3 separate time slots) and Monday, January 23, 2023 (3 separate time slots). We tracked attendance and sent out the recorded training and FAQ sheet to all staff. To ensure a high approval rate, the HR team will run a timecard approval report after each pay period to monitor and track approvals and notify applicable staff of missing timecard approvals. Applicable staff have 2 days to approve their timecard to avoid the implementation of a disciplinary action.