Finding 404544 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-06-28
Audit: 311062
Auditor: Hungerford

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance regarding fringe benefits charged to federal programs without adequate written policies.
  • Impacted Requirements: Noncompliance with 2 CFR 200.431(c), which requires established written policies for allowable fringe benefits.
  • Recommended Follow-Up: Develop and implement formal written policies detailing fringe benefits, including bonuses and retirement contributions, to ensure compliance.

Finding Text

Significant Deficiency in Internal Controls over Compliance (Allowable Costs), and Noncompliance with Laws and Regulations. Condition: Fringe benefits, including bonus distributions and increased Health Savings Account (HSA) and retirement contributions, were provided and charged to federal programs in the absence of adequate written policies and procedures. Programs Affected: Child Welfare Continuum of Care programs; Assistance Listing Numbers: 93.558, 93.658, 93.659, 93.667, 93.778. Criteria: 2 CFR 200.431(c) states that the cost of fringe benefits in the form of employer contributions or expenses for social security; employee life, health, unemployment, and worker’s compensation insurance; pension plan costs; and other similar benefits are allowable, provided such benefits are granted under established written policies. Cause: Original policies and procedures for fringe benefits lacked necessary detail, and subsequent updates have not been made. Effect: Unallowed costs may have been charged to the grant. Questioned Costs: Unknown. Due to MDHHS’s funding methodology for the Continuum of Care grants, the total federal portion of fringe benefits cannot be determined. Context: Fringe benefit policies lacked specificity regarding the process by which benefits such as bonus distributions, and changes to other forms of compensation such as HSA and retirement contributions, were determined. The Organization performed various due diligence activities to support such determinations, including comparability studies and board approval of all decisions made, however written policies to reflect these activities did not exist. Recommendation: The Organization should establish a formal written policy that accurately reflects the fringe benefits charged to federal programs, including but not limited to the bonus structure, retirement contributions, and HSA contributions. Organization’s Response: The Organization agrees with the finding and will implement corrective action to address the condition.

Categories

Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 404542 2023-001
    Significant Deficiency
  • 404543 2023-001
    Significant Deficiency
  • 404545 2023-001
    Significant Deficiency
  • 404546 2023-001
    Significant Deficiency
  • 404547 2023-001
    Significant Deficiency
  • 404548 2023-001
    Significant Deficiency
  • 980984 2023-001
    Significant Deficiency
  • 980985 2023-001
    Significant Deficiency
  • 980986 2023-001
    Significant Deficiency
  • 980987 2023-001
    Significant Deficiency
  • 980988 2023-001
    Significant Deficiency
  • 980989 2023-001
    Significant Deficiency
  • 980990 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.659 Adoption Assistance $2.46M
93.558 Temporary Assistance for Needy Families $1.87M
93.778 Medical Assistance Program $323,823
93.658 Foster Care_title IV-E $6,024
93.667 Social Services Block Grant $5,345