Finding 47425 (2022-002)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2023-02-27
Audit: 52687
Organization: El Hogar Del Nino (IL)

AI Summary

  • Core Issue: Time records for employee compensation charged to federal awards are based on budget estimates rather than actual hours worked, leading to potential inaccuracies in expense allocation.
  • Impacted Requirements: Compliance with Cost Principles for Non-Profit Organizations (2 CFR Part 230) is at risk, as accurate tracking and allocation of employee time to specific activities are not being maintained.
  • Recommended Follow-Up: Implement quarterly time sheet reviews, adjust projected allocations to reflect actual time spent, and provide training for employees on proper time sheet completion to ensure compliance.

Finding Text

2022-002 Allowable Costs/Cost Principles Criteria: Reports reflecting the distribution of activity of each employee must be maintained for all staff members whose compensation is charged, in whole or in part, directly to awards, in accordance with Cost Principles for Non-Profit Organizations (2 CFR Part 230.8). Charges to Federal awards must also be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records must also support the distribution of the employee's salary or 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. Condition: The Organization provided time records that account for the number of hours worked by the selected employees and the departments employees are charged. The Organization is using projected salaries including vacant positions in order to calculate their full-time equivalent rate to be used for administrative allocations and not using actual time. We noted that the expenses are not being properly tracked by federal grant within the general ledger properly to show expenses are not being allocated to multiple grants. Cause: The Organization asserts that time records are consistently maintained to support the allocation of staff time to different functions however, budget estimates are used to support for charges to Federal awards. Effect: Budget estimates (i.e., estimates determined before the services are performed) alone, do not qualify as support for charges to Federal awards. Questioned Costs: None. Recommendation: We again recommend that quarterly recaps of the time sheets be done and that the time analysis be compared to the actual percent being allocated. If necessary, the projected allocation percentages, including full time equivalents, should be changed to reflect the actual time spent as required under 2 CFR 230. Also, the previous quarter should also be adjusted if the revised percentages would cause the financials to be materially misstated. We further again recommend that all employees receive additional training on filling out time sheets and that supervisors receive written procedures on reviewing the time sheets before approving to ensure that they are properly completed. With regards to allocations to awards, we recommend that the Organization properly allocate expenses within the general ledger to reflect the actual expenditures submitted for reimbursement and to ensure no expenses are being reimbursed from multiple grants. Grantee Response: El Hogar del Ni?o will strengthen its internal controls. An expense allocation method will be developed that will more closely reflect the benefit each funding source receives from the expense and is supportable either by an amendable allocation method such as, real time tracking of time, number of students served or square footage to name a few possible examples. Where estimates are used in budgeting, quarterly after-the-fact adjustments will be made when there is a material variance from budget.

Corrective Action Plan

CORRECTIVE ACTION PLAN February 27, 2023 Federal Audit Clearinghouse 1201 E. 10th Street Jeffersonville, IN 47132 El Hogar del Nino (FEIN 36-2749858) respectfully submits the following corrective action plan for the year ended June 30, 2022. Our independent public accounting firm is: Desmond & Ahern, Ltd 10827 S. Western Avenue Chicago, IL 60643 Phone: 773-779-4720 Audit Period: July 1, 2021 through June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2022-002 Allowable Costs/Cost Principles Criteria: Reports reflecting the distribution of activity of each employee must be maintained for all staff members whose compensation is charged, in whole or in part, directly to awards, in accordance with Cost Principles for Non-Profit Organizations (2 CFR Part 230.8). Charges to Federal awards must also be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records must also support the distribution of the employee's salary or 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. Condition: The Organization provided time records that account for the number of hours worked by the selected employees and the departments employees are charged. The Organization is using projected salaries including vacant positions in order to calculate their full-time equivalent rate to be used for administrative allocations and not using actual time. We noted that the expenses are not being properly tracked by federal grant within the general ledger properly to show expenses are not being allocated to multiple grants. Cause: The Organization asserts that time records are consistently maintained to support the allocation of staff time to different functions however, budget estimates are used to support for charges to Federal awards. Effect: Budget estimates (i.e., estimates determined before the services are performed) alone, do not qualify as support for charges to Federal awards. Questioned Costs: None. Recommendation: We again recommend that quarterly recaps of the time sheets be done and that the time analysis be compared to the actual percent being allocated. If necessary, the projected allocation percentages, including full time equivalents, should be changed to reflect the actual time spent as required under 2 CFR 230. Also, the previous quarter should also be adjusted if the revised percentages would cause the financials to be materially misstated. We further again recommend that all employees receive additional training on filling out time sheets and that supervisors receive written procedures on reviewing the time sheets before approving to ensure that they are properly completed. With regards to allocations to awards, we recommend that the Organization properly allocate expenses within the general ledger to reflect the actual expenditures submitted for reimbursement and to ensure no expenses are being reimbursed from multiple grants. Corrective Action Planned: El Hogar del Nino will strengthen its internal controls. An expense allocation method will be developed that will more closely reflect the benefit each funding source receives from the expense and is supportable either by an amendable allocation method such as, real time tracking of time, number of students served or square footage to name a few possible examples. Where estimates are used in budgeting, quarterly after the fact adjustment will be made when there is a material variance from budget. El Hogar del Nino plans to correct this issue by June 30, 2023. Paul DiCaro (CFO Consultant) is responsible for correcting this issue. Paul can be contacted at (224) 229-8250. Sincerely, Paul DiCaro CFO Consultant

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 623867 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $2.78M
10.558 Child and Adult Care Food Program $261,138
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $41,374