Finding 46078 (2022-003)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-06-27
Audit: 40917
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically in tracking hours worked and employee pay rates.
  • Impacted Requirements: The organization failed to ensure that total hours for indirect expense allocation matched timekeeping records, violating 45 CFR 1630.
  • Recommended Follow-Up: Review and update policies to ensure accurate reconciliation of hours and pay rates to prevent future discrepancies.

Finding Text

2022-003 Legal Services Corporation Federal Financial Assistance Listing #09-542026 Legal Services Corporation ? Basic Field Grant Federal Financial Assistance Listing #09-542026 Legal Services Corporation ? Technology Improvement Grant Activities Allowed and Allowable Costs Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1630 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: Total hours and LSC hours worked used to drive monthly allocation of indirect expenses by grant did not agree to total hours and LSC hours worked in the Organization?s timekeeping software for eight of the twelve months. Additionally, one instance identified in which the rate of pay paid to an employee did not agree to the approved rate of pay. Cause: There was a lapse in oversight of the internal control process ensuring total hours used to allocate indirect expenses by grant reconciled to total hours worked out of the Organization?s timekeeping software. There was a clerical error in revising the pay rate for an employee that was undetected by the payroll review process. Effect: The Organization?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Organization could submit disallowed costs under the federal award. Questioned Costs: None reported. The error resulted in the federal award being undercharged. Context/Sampling: Total hours and LSC hours worked within the fiscal year was tested in total. A nonstatistical sample of 6 out of 26 pay periods was selected for internal control testing over the compliance requirement. Repeat Finding from Prior Year: No Recommendation: We recommend the Organization to review policies and procedures to ensure total hours used to allocate monthly indirect expenses reconcile to hours worked per the Organization?s timekeeping software. Additionally, we recommend the Organization to review policies and procedures to ensure employee?s rate of pay paid agrees to their approved rate of pay. Views of Responsible Officials: Management is in agreement.

Corrective Action Plan

Finding 2022-003 Federal Agency Name: Legal Services Corporation Program Name: LSC Basic Field Grant; LSC Technology Improvement Grant. CFDA#: 09-542026 Finding Summary: Total hours and LSC hours worked used to drive monthly allocation of indirect expenses by grant did not agree to total hours and LSC hours worked in the Organization?s timekeeping software for eight of the twelve months. Additionally, one instance identified in which the rate of pay paid to an employee did not agree to the approved rate of pay. Responsible Individuals: Kathy Schroeder, 3rd party accountant, and Lea Wroblewski, Executive Director. Corrective Action Plan: Additional procedures are being followed to ensure that the timekeeping software is completed on a timely basis and locked down by the Executive Director or Technology Consultant when all entries have been made and reviewed. The time report used for the indirect expense allocations is not processed until the software is locked down. All changes to employees pay calculation are made after the submission of an approved Personnel Action Form is provided to the staff accountant. Each payroll is then reviewed by the Executive Director and a board member before processing. Completion Date: 06/30/2023

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Material Weakness

Other Findings in this Audit

  • 46079 2022-003
    Material Weakness
  • 622520 2022-003
    Material Weakness
  • 622521 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
09.GSA_MIGRATION Basic Field Grant $509,273
16.575 Crime Victim Assistance $449,873
09.GSA_MIGRATION Lsc Tech Improvement Grant $30,868
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $13,365