Finding 401280 (2023-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2023

Accepted

2024-06-20

Audit: 309321

Organization: American Society of Nephrology, Inc. (DC)

Auditor: Rogers & Company CPAS PLLC

AI Summary

Core Issue: Payroll expenses were allocated based on budgeted amounts instead of actual timesheets from January to June 2023.
Impacted Requirements: Costs must be backed by proper documentation, including signed timesheets, as per Uniform Guidance.
Recommended Follow-Up: Establish internal policies to ensure all payroll expenses are reviewed and approved based on actual time records.

Finding Text

ALN: 93.318 and 93.083 Condition: The Organization allocated the payroll expenses to the grants using budgeted amounts rather than by actual timesheets from January 2023 to June 2023. Criteria: Under the Uniform Guidance, the costs need to be supported by appropriate documentation and time records such as signed and approved timesheets with hours allocated to be charged to the grants. Cause: Lack of specific controls and procedures to ensure compliance for payroll expenses incurred to the grants. Effect: Without proper controls in place for payroll allocation by employee timesheets, the Organization is at risk of making a disallowed expenditure for expenditures incurred. Questioned Costs: None. Context: The Organization did not allocate payroll expenses on an individual timesheet basis from January 2023 to June 2023. The Organization allocated payroll expenses based on effort and applied a percentage accordingly using gross pay to individual departments and programs from January 2023 to June 2023. Identification as a Repeat Finding: Yes. Repeat finding of 2022-003. Recommendation: We recommend that the Organization implement internal policies and procedures regarding the allowability of costs in that all expenditures are reviewed and approved by the appropriate individual in order to determine whether the expense amount is correct, properly recorded, and properly supported by either an invoice or timesheet. Views of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.

Corrective Action Plan

Finding No. 2023-001 – Significant Deficiency – Payroll Timesheet Allocation ALN: 93.318 and 93.083 Recommendation: We recommend that the Organization implement internal policies and procedures regarding the allowability of costs in that all expenditures are reviewed and approved by the appropriate individual in order to determine whether the expense amount is correct, properly recorded, and properly supported by either an invoice or timesheet. Views of Responsible Officials and Planned Corrective Action: Management agrees to the recommendation. From January 1 to June 30, 2023, the Organization allocated its time on federal grants by the anticipated percentage of time each employee worked on the project by month. After the 2022 audit was completed, and beginning July 1, 2023, the Organization implemented a timesheet process for all employees. Each employee documented how many hours they spent on each project every day. After the 15th and the last day of the month, all employees certify the accuracy of their timesheet and submit it to their supervisor for approval. Views of Responsible Officials and Planned Corrective Action (continued): Once reviewed for accuracy and certified by the supervisor, the timesheets are saved in an online repository. The hours spent on each project are used to calculate the costs incurred by the Organization each period. The Organization is still in the process of implementing an organization-wide timekeeping system that will be integrated into its financial and human resources systems in the future. Person Responsible: Tod Ibrahim Executive Vice President tibrahim@asn-online.org 202-640-4660 Planned Completion Date: December 31, 2024 American

Other Findings in this Audit

401281 2023-001

Significant Deficiency Repeat
977722 2023-001

Significant Deficiency Repeat
977723 2023-001

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
93.318	Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security	$646,628
93.083	Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases	$586,481
93.103	Food and Drug Administration_research	$300,000