Finding 46715 (2022-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-09-28
Audit: 40819
Organization: Awaiaulu, Inc. (HI)

AI Summary

  • Core Issue: The organization failed to properly document how nonpayroll costs and salaries were allocated to federal programs.
  • Impacted Requirements: Noncompliance with Sections 200.405 and 200.430 of the Uniform Guidance regarding cost allocation and accurate record-keeping.
  • Recommended Follow-Up: Implement a system to maintain documentation for cost allocations and ensure salaries reflect actual work performed.

Finding Text

Finding 2022-001 U.S. Department of Education Native Hawaiian Education Assistance Listing No. 84.362A Criteria ? Under Section 200.405 of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined, the costs may be allocated on a reasonable documented basis. Under Section 200.430 of the Uniform Guidance, salaries and wages charged to federal awards must be based on records that accurately reflect the work performed. Condition ? During the audit for the year ended December 31, 2022, the bases used to allocate nonpayroll costs to two or more programs were not adequately documented. In addition, salaries and wages charged to federal awards were not based on records that accurately reflected the work performed. Cause ? The Organization did not document the basis for the allocation of nonpayroll costs to its various federal programs. The Organization did not maintain records that accurately reflected the work performed on its federal programs. Salaries and wages charged to federal awards were based on budgeted amounts. Effect or Potential Effect ? Nonpayroll costs that benefit more than one federal program may be misallocated among federal and other programs. Salaries and wages for employees who work on more than one federal program may be misallocated among federal and other programs. Questioned Costs ? Unknown. Context ? The Organization had $573,039 in nonpayroll costs and $417,366 in salaries and wages included in its federal expenditures during the year ended December 31, 2022. Recommendation ? Maintain documentation to support the allocation of nonpayroll costs between two or more programs. Maintain documentation, such as a timesheet or certified statement, to substantiate the salaries and wages charged to the federal programs that is based on the actual time worked by personnel. Responsible Official?s Response and Corrective Action Planned ? Refer to the Corrective Action Plan.

Corrective Action Plan

The allocation of costs between our two federal programs and other programs are made by the Program Director or after discussion between the Program Director and the Federal Grant Manager; then communicated to the accountant. In addition, our accountant has the program knowledge and ability to question cost allocations. Beginning mid-September, 2023, the basis for allocations will be documented on an invoice or other supporting documents. Effective June 2023, weekly payroll time records allocating hours to projects and programs are prepared by each employee. Those time records are approved by the Program Director or the Treasurer, as appropriate. The allocations are then reviewed by the Federal Grant Manager and entered bi-weekly into the accounting records.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 46716 2022-002
    Significant Deficiency
  • 623157 2022-001
    Significant Deficiency
  • 623158 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.362 Native Hawaiian Education $731,483
93.612 Native American Programs $258,922