Finding 45776 (2022-001)

Finding 2022-001 Federal Award Program: Emergency Rental Assistance Program (Assistance Listing # 21.023) Pass-through Agency: Lane County Type of Finding: Significant deficiency in internal controls over compliance Compliance Requirement: Allowable costs Criteria: The Uniform Guidance (2 CFR ?200.430) states that costs of compensation are allowable to the extent they are reasonable for the services rendered and conform to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; and follow an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable. ShelterCare?s written policies rely on the use of timesheets, activity reports (which document actual hours worked by program/grant) and an excel billing worksheet to charge time to federal program grants. Condition: We noted instances in which the internal control policies were inconsistently applied to the process of recording and billing employees? time. We also noted instances in which time sheets and activity reports were missing employee and supervisor signatures indicating approval. We also noted instances in which information from the activity reports did not agree to the underlying timesheets. Cause of Condition: Internal control policies and procedures were not consistently applied to the process for timesheet review and approval, completion of activity reports and preparation of billings for the federal program grants. There was not adequate review of the billings against the underlying support (timesheets and activity reports) to catch input errors in the billings. Effect of Condition: This condition increases the risk that the incorrect amount of costs and/or unallowable costs would be charged to the federal program. Questioned Costs: No reportable questioned costs. Context: Our sample size was 40 payroll transactions and was not a statistically valid sample as it was selected haphazardly. We noted two instances in our sample in which timesheets and activity reports were missing employee and supervisor signatures indicating approval. We noted two instances in which information input into the billing did not agree to the underlying data in the activity reports and timesheets. Repeat Finding: No. Recommendation: We recommend management review the current process used to transfer data from the timesheet to the activity report to the billing worksheets and institute additional layers of review of the data to ensure data is accurately allocated and reported in the billing worksheets for which the costs charged to the grants are derived. We also recommend management consistently apply procedures to ensure activity reports are completed for all employees charging time to programs and appropriate approvals are obtained prior to billings. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.