Finding 478873 (2023-003)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-07-19
Audit: 315495
Organization: Harvest Against Hunger (WA)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to payroll allocation for federal awards.
  • Impacted Requirements: The organization is not following §200.303 and §200.430(i), which require accurate documentation of payroll based on actual work performed.
  • Recommended Follow-Up: Implement consistent policies for time allocation and strengthen internal controls to ensure accurate documentation of payroll expenses.

Finding Text

Type of Finding: "• Significant Deficiency in Internal Control over Compliance" Criteria or specific requirement: Per §200.303, non-Federal entities must "establish and 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." Additionally, non-Federal entities must charge salaries and wages "based on records that accurately reflect the work performed" (§200.430(i)). Condition: Harvest Against Hunger allocates costs to the program based on the available funding and number of employees working on the project. They do not use the timesheet to record the operating hours for the program, but rather management makes a judgmental decision based on their understanding of program operations during the payroll period. Questioned costs: None Cause: The Organization lacks documentation supporting the allocation determination used to determine payroll amounts charged to the major program. Effect: Without proper documentation of the payroll allocation used, the Organization could charge time to a federal program that does not reflect true expenditures incurred by that program. Repeat Finding: This is not a repeated finding. Recommendation: The Organization should implement policies for consistently determining time allocation to the federal program, and ensure internal controls help to ensure this allocation is correct and consistently documented. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s): E128H7X5KWX5 Award Period: 7/1/21-6/30/23; 11/19/21-6/30/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Section III – Findings and Questioned Costs – Major Federal Programs Condition: Harvest Against Hunger allocates costs to the program based on the available funding and number of employees working on the project. They do not use the timesheet to record the operating hours for the program, but rather management makes a judgmental decision based on their understanding of program operations during the payroll period. Questioned costs: None Cause: The Organization lacks documentation supporting the allocation determination used to determine payroll amounts charged to the major program. Views of responsible officials: There is no disagreement with the finding. Criteria or specific requirement: Per §200.303, non-Federal entities must "establish and 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." Additionally, non-Federal entities must charge salaries and wages "based on records that accurately reflect the work performed" (§200.430(i)). Effect: Without proper documentation of the payroll allocation used, the Organization could charge time to a federal program that does not reflect true expenditures incurred by that program. Repeat Finding: This is not a repeated finding. Recommendation: The Organization should implement policies for consistently determining time allocation to the federal program, and ensure internal controls help to ensure this allocation is correct and consistently documented

Categories

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 478874 2023-003
    Significant Deficiency
  • 1055315 2023-003
    Significant Deficiency
  • 1055316 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
94.013 Volunteers in Service to America $44,882
21.027 Coronavirus State and Local Fiscal Recovery Funds $37,446