FAC Explorer

Finding 392935 (2023-002)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-04-10
Audit: 303212
Organization: City of Columbus, Ohio (OH)
Auditor: Ohio Auditor of State

AI Summary

  • Core Issue: Supervisors are not consistently signing timesheets within the required one-week timeframe, leading to potential compliance risks.
  • Impacted Requirements: Internal controls under 2 CFR §200.430(i)(1)(i) and City policies for timely supervisor review of timesheets.
  • Recommended Follow-Up: Review and reinforce policies with supervisors; consider additional controls to ensure timely timesheet approvals.

Finding Text

2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the 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 be in compliance with 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). Furthermore, 2 CFR §200.430(i)(1)(i) states "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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet. While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. Payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 13 out of the 19 selected worklogs (68%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 7 and 102 working days (not including weekends) following the end of the pay period. Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.

Corrective Action Plan

Finding Number: 2023-002 Planned Corrective Action: The City concurs with the finding and will take the following actions in response: Provide training in the Department of Development (DOD) that reminds applicable staff of the department’s policy that all personal activity reports/work logs are to be reviewed and signed by the supervisor within one week of the completion of a pay period. Modify current financial management internal controls to indicate that if a work log is not signed by the supervisor at the time DOD Fiscal Office completes the quarterly ‘tru up’, a ‘tru up’ for unsigned activity reports/work logs shall not be done at that time, thereby reducing the risk of ineligible expenses, and all worklogs must be signed by the time designated by DOD Fiscal Office near the end of the fiscal year; and DOD Fiscal Office staff shall review signature timeliness as a part of the quarterly ‘tru up’ process and provide a report to department leadership who shall determine the appropriate next steps if activity reports/work logs are unsigned. Anticipated Completion Date: 4/30/2024 Responsible Contact Person: Bill Webster, Deputy Director Alex Cofield, Development Program Coordinator/Compliance and Data Analytics

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 392929 2023-001
    Material Weakness Repeat
  • 392930 2023-001
    Material Weakness
  • 392931 2023-001
    Material Weakness
  • 392932 2023-001
    Material Weakness
  • 392933 2023-001
    Material Weakness
  • 392934 2023-001
    Material Weakness
  • 969371 2023-001
    Material Weakness Repeat
  • 969372 2023-001
    Material Weakness
  • 969373 2023-001
    Material Weakness
  • 969374 2023-001
    Material Weakness
  • 969375 2023-001
    Material Weakness
  • 969376 2023-001
    Material Weakness
  • 969377 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $125.78M
66.458 Capitalization Grants for Clean Water State Revolving Funds $51.78M
21.023 Emergency Rental Assistance $36.46M
20.205 Highway Planning and Construction $25.77M
14.218 Community Development Block Grants/entitlement Grants $18.01M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $12.94M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $6.43M
93.914 Hiv Emergency Relief Project Grants $4.41M
14.239 Home Investment Partnerships Program $4.40M
93.940 Hiv Prevention Activities_health Department Based $2.59M
16.922 Equitable Sharing Program $2.46M
93.053 Nutrition Services Incentive Program $2.42M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $2.27M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $2.03M
14.241 Housing Opportunities for Persons with Aids $1.93M
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $1.31M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $1.22M
93.926 Healthy Start Initiative $1.21M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $1.12M
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $1.05M
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $1.05M
93.268 Immunization Cooperative Agreements $1.00M
10.559 Summer Food Service Program for Children $918,577
93.069 Public Health Emergency Preparedness $916,673
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B (b) $734,664
93.052 National Family Caregiver Support, Title Iii, Part E $676,220
21.027 Coronavirus State and Local Fiscal Recovery Funds $644,154
14.231 Emergency Solutions Grant Program $640,625
93.217 Family Planning_services $588,158
93.305 National State Based Tobacco Control Programs $567,044
93.994 Maternal and Child Health Services Block Grant to the States $538,714
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $377,126
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $349,512
14.913 Healthy Homes Production Program $309,682
16.741 Dna Backlog Reduction Program $255,251
10.576 Senior Farmers Market Nutrition Program $241,293
16.575 Crime Victim Assistance $223,004
20.600 State and Community Highway Safety $218,414
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $213,218
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $191,088
93.145 Aids Education and Training Centers $190,724
16.585 Drug Court Discretionary Grant Program $181,544
16.588 Violence Against Women Formula Grants $174,884
93.991 Preventive Health and Health Services Block Grant $142,340
93.137 Community Programs to Improve Minority Health Grant Program $134,156
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $129,545
16.738 Edward Byrne Memorial Justice Assistance Grant Program $125,550
93.136 Injury Prevention and Control Research and State and Community Based Programs $119,474
87.002 Virginia Graeme Baker Pool and Spa Safety $109,150
21.016 Equitable Sharing $104,408
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $93,183
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $81,085
93.071 Medicare Enrollment Assistance Program $73,821
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $66,531
93.279 Drug Abuse and Addiction Research Programs $52,660
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $51,512
93.568 Low-Income Home Energy Assistance $48,674
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $48,107
97.091 Homeland Security Biowatch Program $46,776
97.012 Boating Safety Financial Assistance $46,632
93.387 National and State Tobacco Control Program (b) $44,897
93.788 Opioid Str $41,787
16.838 Comprehensive Opioid Abuse Site-Based Program $39,347
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $37,501
16.034 Coronavirus Emergency Supplemental Funding Program $28,812
93.889 National Bioterrorism Hospital Preparedness Program $21,216
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $14,181
93.516 Affordable Care Act (aca) Public Health Training Centers Program $11,921
66.046 Climate Pollution Reduction Grants $9,794
21.019 Coronavirus Relief Fund $9,197
16.726 Juvenile Mentoring Program $5,965