We acknowledge the findings from the audit of our federal grants award, specifically the
insufficient documentation of time and effort for one of our employees. We understand the
importance of adhering to 2 CFR part 200.430 of the Uniform Guidance and regret any
discrepancies that occurred. The single discrepancy noted related to a new employee that was
hired for the federal grant a month and half before the end of the grant year. The variance
resulted from an inadvertent payroll coding error in the payroll system, where the employee’s
time and effort for the grant was miscoded. We appreciate the opportunity to address this finding
and are committed to preventing its recurrence. Below, please find the detailed corrective action
plan with timelines and responsible parties.
Corrective Action Plan
1 Review and Correction:
- We wish to assure you that this was an isolated incident resulting from a clerical
oversight. As soon as the discrepancy was brought to our attention, corrective measures
were promptly taken. The incorrect coding has been rectified in the payroll system.
- Further, we have reviewed the documentation for the employee in question to established
that the employee subsequent records accurately reflected the time and effort spent on the
federal program.
2 Policy Review and Update:
- We have reviewed our time and effort documentation procedures to ensure they align
with federal requirements and would consistently lead to a fair and accurate time and
effort allocation.
- We noted that our current policy and procedures are adequate but can be strengthened
further by a more effective supervisory review of time sheets for each employee assigned
to a federal grant.
- Nevertheless, all changes in policies and procedures that result in our continuous review
will be documented and communicated to relevant personnel.
- Updated procedures will be incorporated into our organizational handbook and made
accessible to all staff members.
- Further, we will ensure federal program managers are aware of any changes in
regulations or requirements. This proactive approach will help us stay updated and adjust
our procedures accordingly.
3 Staff Training:
- We will, additionally, require all staff involved in federal grants to undergo quarterly
training to reinforce the importance of accurate time and effort reporting. This training
will cover the proper use of our time reporting system and the necessity of aligning it
with accounting records. Our training sessions will cover the requirements of 2 CFR part
200.430 and the specific procedures that must be followed to maintain compliance.
4 Enhanced Oversight and Monitoring:
- A system of regular internal audits will be established to monitor the compliance of time
and effort documentation.
- These audits will be conducted quarterly, and any discrepancies will be promptly
addressed to ensure continuous compliance.
5 Continuous Improvement:
- We commit to continuously improving our processes and controls related to federal grant
management. This will include seeking feedback from our staff and auditors to identify
areas for further enhancement.
We believe that these corrective actions address the identified deficiency and goes beyond with
additional effort to enhance our compliance environment. As a company, we are committed to
maintaining the highest standards of accuracy and accountability to manage our federal funds.