Finding 396683 (2023-002)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-05-14
Audit: 306294
Organization: Accounting Aid Society (MI)

AI Summary

  • Core Issue: Inadequate controls led to personnel expenses being charged to the wrong grant cost center.
  • Impacted Requirements: Violates Section 2 CFR Part 200.430, which requires accurate timekeeping records for salary allocations.
  • Recommended Follow-Up: Implement a system for tracking actual hours worked by grant to ensure compliance with federal documentation standards.

Finding Text

Criteria According to Section 2 CFR Part 200.430 (i) Standard for Documentation of Personnel Expenses, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award, a federal award, and a non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition Controls were inadequate to ensure the Organization maintains timekeeping documentation by grant. Context During the testing of the allowability of expenses, we discovered personnel expenses were charged to the incorrect grant cost center. Management allocates actual personnel expenses based on the grant budgeted amount instead of actual hours worked by the grant area. Management does not require personnel to track actual time spent by the grant. Cause and Effect The Organization did not fully follow the guidance detailed in Section 2 CFR Part 200.430 to ensure that payroll expense allocations are based on actual time spent instead of grant budgeted amounts.

Corrective Action Plan

Upon review of the finding, we acknowledge the importance of accurately documenting personnel expenses by the requirements outlined in the cited regulation. We recognize that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and that these records must support the distribution of an employee's salary or wages among specific activities or cost objectives when applicable. In response to this finding, we will take the following actions: 1. Review and strengthen our current procedures for documenting personnel expenses to ensure compliance with Section 2 CFR Part 200.430 (i). 2. Provide additional training and guidance to relevant personnel responsible for documenting time and effort across different activities or cost objectives. 3. Implement enhanced monitoring mechanisms to regularly assess and validate the completeness of personnel expense documentation. 4. Designate a responsible individual or team to oversee and coordinate the implementation of these corrective actions. We are fully committed to addressing this finding promptly and effectively to ensure ongoing compliance with federal regulations. We welcome any further guidance or assistance from your team to facilitate this process.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 396682 2023-001
    Significant Deficiency
  • 973124 2023-001
    Significant Deficiency
  • 973125 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $200,000
93.137 Community Programs to Improve Minority Health Grant Program $124,461
14.218 Community Development Block Grants/entitlement Grants $90,282
93.568 Low-Income Home Energy Assistance $60,000
21.008 Low Income Taxpayer Clinics $50,000
59.077 Community Navigator Pilot Program $27,714