FAC Explorer

Finding 449482 (2022-006)

Significant Deficiency
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-03-30
Audit: 313273
Organization: Baltimore County, Maryland (MD)
Auditor: Cliftonlarsonallen

AI Summary

  • Core Issue: The County failed to document Time and Effort Certifications properly, leading to inadequate support for payroll expenses charged to federal programs.
  • Impacted Requirements: Compliance with 2 CFR Section 200.430 on documentation of personnel expenses and internal control standards under 2 CFR 200.303(a) was not met.
  • Recommended Follow-Up: The County should improve its controls, provide training on time and effort reporting, and avoid seeking federal reimbursement until compliance is ensured.

Finding Text

Reference Number: 2022-006Federal Agency: U.S. Department of Housing and Urban DevelopmentFederal Program: CDBG Entitlement Grant ClusterAssistance Listing Number: 14.218Award Number and Period: B-21-UC-24-0011, B-20-UW-24-0011Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect work performed. These records must:(i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;(iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy;(v) Comply with the established accounting policies and practices of the non-Federal entity;(vi) Support the distribution of the employee's salary and wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and 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.Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish an maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 5 of 40 time and effort certifications tested.Cause:The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements.Effect:There is an increased risk of charging unallowed payroll costs to the program.Questioned Costs:$3,494Recommendation:The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Views of Responsible Officials:See separate Correction Action Plan related to this finding.

Corrective Action Plan

2022-006 CDBG Entitlement Grant Cluster ? Assistance Listing No. 14.218Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DHCD follows Baltimore County?s general payroll policies and procedures. DHCD allocates time and attendance based on a preset budgeted formula and monitors the staff?s time and attendance through biweekly timesheet prepared by the staff members and approved by unit managers and the review of payroll register. Baltimore County is discontinuing the use of current payroll system CGI Advantage and will be migrating to Workday system which has more robust features and capabilities to capture time and attendance.Name(s) of the contact person(s) responsible for corrective action: Amir AssadiPlanned completion date for corrective action plan: 7/1/2023

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 449481 2022-002
    Material Weakness Repeat
  • 449483 2022-003
    Significant Deficiency
  • 449484 2022-003
    Significant Deficiency
  • 449485 2022-006
    Significant Deficiency
  • 449486 2022-002
    Significant Deficiency
  • 449487 2022-001
    Significant Deficiency
  • 449488 2022-001
    Significant Deficiency
  • 449489 2022-001
    Significant Deficiency
  • 449490 2022-001
    Significant Deficiency
  • 449491 2022-001
    Significant Deficiency
  • 449492 2022-001
    Significant Deficiency
  • 449493 2022-001
    Significant Deficiency
  • 449494 2022-004
    Material Weakness
  • 449495 2022-007
    Significant Deficiency
  • 449496 2022-001
    Significant Deficiency
  • 449497 2022-008
    Significant Deficiency
  • 449498 2022-005
    Significant Deficiency
  • 449499 2022-005
    Significant Deficiency
  • 449500 2022-008
    Significant Deficiency
  • 449501 2022-001
    Significant Deficiency
  • 449502 2022-001
    Significant Deficiency
  • 449503 2022-001
    Significant Deficiency
  • 449504 2022-001
    Significant Deficiency
  • 449505 2022-001
    Significant Deficiency
  • 449506 2022-001
    Significant Deficiency
  • 449507 2022-001
    Significant Deficiency
  • 449508 2022-001
    Significant Deficiency
  • 449509 2022-001
    Significant Deficiency
  • 1025923 2022-002
    Material Weakness Repeat
  • 1025924 2022-006
    Significant Deficiency
  • 1025925 2022-003
    Significant Deficiency
  • 1025926 2022-003
    Significant Deficiency
  • 1025927 2022-006
    Significant Deficiency
  • 1025928 2022-002
    Significant Deficiency
  • 1025929 2022-001
    Significant Deficiency
  • 1025930 2022-001
    Significant Deficiency
  • 1025931 2022-001
    Significant Deficiency
  • 1025932 2022-001
    Significant Deficiency
  • 1025933 2022-001
    Significant Deficiency
  • 1025934 2022-001
    Significant Deficiency
  • 1025935 2022-001
    Significant Deficiency
  • 1025936 2022-004
    Material Weakness
  • 1025937 2022-007
    Significant Deficiency
  • 1025938 2022-001
    Significant Deficiency
  • 1025939 2022-008
    Significant Deficiency
  • 1025940 2022-005
    Significant Deficiency
  • 1025941 2022-005
    Significant Deficiency
  • 1025942 2022-008
    Significant Deficiency
  • 1025943 2022-001
    Significant Deficiency
  • 1025944 2022-001
    Significant Deficiency
  • 1025945 2022-001
    Significant Deficiency
  • 1025946 2022-001
    Significant Deficiency
  • 1025947 2022-001
    Significant Deficiency
  • 1025948 2022-001
    Significant Deficiency
  • 1025949 2022-001
    Significant Deficiency
  • 1025950 2022-001
    Significant Deficiency
  • 1025951 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $78.93M
21.023 Emergency Rental Assistance Program $43.03M
14.239 Home Investment Partnerships Program $32.79M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $12.25M
21.019 Coronavirus Relief Fund $7.81M
14.231 Emergency Solutions Grant Program $2.15M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $2.12M
14.218 Community Development Block Grants/entitlement Grants $2.10M
14.241 Housing Opportunities for Persons with Aids $1.82M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $1.54M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $1.53M
93.558 Temporary Assistance for Needy Families $1.39M
17.259 Wia Youth Activities $1.32M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.27M
93.568 Low-Income Home Energy Assistance $1.05M
11.307 Economic Adjustment Assistance $1.05M
93.778 Medical Assistance Program $909,146
14.267 Continuum of Care Program $887,729
93.658 Foster Care_title IV-E $786,975
17.235 Senior Community Service Employment Program $686,520
93.069 Public Health Emergency Preparedness $549,190
97.067 Homeland Security Grant Program $509,781
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $500,993
10.551 Supplemental Nutrition Assistance Program $497,685
93.563 Child Support Enforcement $488,749
17.258 Wia Adult Program $437,248
97.042 Emergency Management Performance Grants $404,631
16.922 Equitable Sharing Program $388,308
93.268 Immunization Cooperative Agreements $384,974
93.958 Block Grants for Community Mental Health Services $378,367
21.016 Equitable Sharing $365,122
93.940 Hiv Prevention Activities_health Department Based $340,320
93.788 Opioid Str $326,394
16.710 Public Safety Partnership and Community Policing Grants $300,955
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $284,432
14.896 Family Self-Sufficiency Program $256,163
93.959 Block Grants for Prevention and Treatment of Substance Abuse $253,254
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $193,600
14.905 Lead Hazard Reduction Demonstration Grant Program $169,714
14.235 Supportive Housing Program $164,473
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $161,983
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $152,964
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $132,893
16.575 Crime Victim Assistance $127,449
93.767 Children's Health Insurance Program $125,756
17.270 Reintegration of Ex-Offenders $123,950
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $112,059
93.053 Nutrition Services Incentive Program $110,655
16.999 N/a $105,342
16.738 Edward Byrne Memorial Justice Assistance Grant Program $100,000
93.150 Projects for Assistance in Transition From Homelessness (path) $94,200
17.278 Wia Dislocated Worker Formula Grants $84,519
94.002 Retired and Senior Volunteer Program $65,623
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $63,648
93.914 Hiv Emergency Relief Project Grants $52,798
16.034 Coronavirus Emergency Supplemental Funding Program $45,000
84.181 Special Education-Grants for Infants and Families $41,738
93.071 Medicare Enrollment Assistance Program $39,756
16.607 Bulletproof Vest Partnership Program $32,305
93.590 Community-Based Child Abuse Prevention Grants $30,000
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $28,958
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $28,814
16.741 Dna Backlog Reduction Program $27,708
16.588 Violence Against Women Formula Grants $25,435
21.999 N/a $22,998
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $19,394
20.218 National Motor Carrier Safety $16,897
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $15,836
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $13,088
97.039 Hazard Mitigation Grant $11,713
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $11,697
16.833 National Sexual Assault Kit Initiative $11,513
20.509 Formula Grants for Rural Areas and Tribal Transit Program $10,089
93.324 State Health Insurance Assistance Program $5,250
20.600 State and Community Highway Safety $5,200
93.994 Maternal and Child Health Services Block Grant to the States $4,284
17.277 Workforce Investment Act (wia) National Emergency Grants $3,882
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $3,839
97.044 Assistance to Firefighters Grant $3,684
93.052 National Family Caregiver Support, Title Iii, Part E $3,666
10.168 Farmers' Market and Local Food Promotion Program $1,518
93.043 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,200
93.917 Hiv Care Formula Grants $617
16.754 Harold Rogers Prescription Drug Monitoring Program $474