Finding 394804 (2023-004)

Significant Deficiency Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-04-26
Audit: 304646
Organization: United Way of Greater Cleveland (OH)
Auditor: Bdo USA LLP

AI Summary

  • Core Issue: United Way of Greater Cleveland inadequately documented payroll costs for the Title XX federal program, leading to potential noncompliance.
  • Impacted Requirements: Failure to meet CFR 200.403(g) documentation standards for allowable costs may jeopardize funding.
  • Recommended Follow-Up: Develop a policy for monthly analysis of actual costs and ensure all invoiced hours are supported by timecards before submission.

Finding Text

2023-004 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.667 Assistance Listing Name: Social Services Block Grant Pass-through Awards under the Uniform Guidance Requirements: Criteria – CFR 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition – During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the United Way of Greater Cleveland’s Title XX federal program. The Organization billed for personnel time on a monthly basis (1/12 of the total award) up to the maximum available for personnel costs, versus billing for the actual costs incurred under the award. The United Way of Greater Cleveland did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. Rather, United Way of Greater Cleveland allocated the time and effort of employees at the end of the fiscal year to ensure that costs incurred were not less than total reimbursements, and no programs were overbilled for the annual costs under the program. In performing the allocation in this manner, United Way inadvertently overallocated time charges to the Title XX program, however, total costs incurred by United Way after exclusion of the overallocation were not in excess of the amounts funded by the program. Cause – United Way does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged to federal programs. Effect – An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs – None. Context – United Way of Greater Cleveland collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure does not exist to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing. Rather, invoicing is done on a pro-rata basis for the entire amount of the personnel cost under the contract, and then an annual comparison to contract was done across programs to provide greater assurance that no costs had been billed and reported in excess of the amounts incurred. Repeat Finding – This is a repeat finding.Recommendation - We recommend that United Way of Greater Cleveland develop a policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation, thus demonstrating the level of effort under the uniform guidance. We further recommend that management review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding and the recommendation.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 394780 2023-001
    Significant Deficiency Repeat
  • 394781 2023-001
    Significant Deficiency Repeat
  • 394782 2023-001
    Significant Deficiency Repeat
  • 394783 2023-001
    Significant Deficiency Repeat
  • 394784 2023-001
    Significant Deficiency Repeat
  • 394785 2023-001
    Significant Deficiency Repeat
  • 394786 2023-001
    Significant Deficiency Repeat
  • 394787 2023-001
    Significant Deficiency Repeat
  • 394788 2023-001
    Significant Deficiency Repeat
  • 394789 2023-001
    Significant Deficiency Repeat
  • 394790 2023-001
    Significant Deficiency Repeat
  • 394791 2023-002
    Significant Deficiency
  • 394792 2023-002
    Significant Deficiency
  • 394793 2023-002
    Significant Deficiency
  • 394794 2023-002
    Significant Deficiency
  • 394795 2023-002
    Significant Deficiency
  • 394796 2023-002
    Significant Deficiency
  • 394797 2023-002
    Significant Deficiency
  • 394798 2023-002
    Significant Deficiency
  • 394799 2023-002
    Significant Deficiency
  • 394800 2023-002
    Significant Deficiency
  • 394801 2023-002
    Significant Deficiency
  • 394802 2023-003
    Significant Deficiency
  • 394803 2023-004
    Significant Deficiency Repeat
  • 394805 2023-005
    Significant Deficiency Repeat
  • 394806 2023-006
    Significant Deficiency
  • 394807 2023-006
    Significant Deficiency
  • 971222 2023-001
    Significant Deficiency Repeat
  • 971223 2023-001
    Significant Deficiency Repeat
  • 971224 2023-001
    Significant Deficiency Repeat
  • 971225 2023-001
    Significant Deficiency Repeat
  • 971226 2023-001
    Significant Deficiency Repeat
  • 971227 2023-001
    Significant Deficiency Repeat
  • 971228 2023-001
    Significant Deficiency Repeat
  • 971229 2023-001
    Significant Deficiency Repeat
  • 971230 2023-001
    Significant Deficiency Repeat
  • 971231 2023-001
    Significant Deficiency Repeat
  • 971232 2023-001
    Significant Deficiency Repeat
  • 971233 2023-002
    Significant Deficiency
  • 971234 2023-002
    Significant Deficiency
  • 971235 2023-002
    Significant Deficiency
  • 971236 2023-002
    Significant Deficiency
  • 971237 2023-002
    Significant Deficiency
  • 971238 2023-002
    Significant Deficiency
  • 971239 2023-002
    Significant Deficiency
  • 971240 2023-002
    Significant Deficiency
  • 971241 2023-002
    Significant Deficiency
  • 971242 2023-002
    Significant Deficiency
  • 971243 2023-002
    Significant Deficiency
  • 971244 2023-003
    Significant Deficiency
  • 971245 2023-004
    Significant Deficiency Repeat
  • 971246 2023-004
    Significant Deficiency Repeat
  • 971247 2023-005
    Significant Deficiency Repeat
  • 971248 2023-006
    Significant Deficiency
  • 971249 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.667 Social Services Block Grant $277,769
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $198,182
93.558 Temporary Assistance for Needy Families $196,731
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $123,378
93.052 National Family Caregiver Support, Title Iii, Part E $110,721
93.650 Accountable Health Communities $65,675
97.024 Emergency Food and Shelter National Board Program $39,171
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $12,185
93.268 Immunization Cooperative Agreements $7,500
14.218 Community Development Block Grants/entitlement Grants $312