Finding Text
Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity 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 statutes, regulations, and the terms and conditions of the federal award. According to §200.430(i) Standards for Documentation of Personnel Expenses of 2 CFR Part 200, (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
i. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
ii. Be incorporated into the official records of the non-Federal entity;
iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
iv. Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy;
v. Comply with the established accounting policies and practices of the non-Federal entity; and
vi. 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.
According to the Authority’s policies and procedures, for employees working in a single indirect cost function, such as overhead, a Budget Analyst compares the salary budgets with actual salary allocations and investigates unusual variances. This review is performed on the first pay run of the fiscal year and at the end of every quarter. If the investigation determines that the salary allocation is no longer valid, the Department can request a change in allocation rates. Allocation changes can only be changed in the Enterprise One (E1) system by the payroll manager, or the budget analyst assigned to the overhead account. Employees engaged in multiple direct cost business units and projects, and indirect overhead activity, may have their labor distribution entered in E1 as a predetermined (budgeted) allocation of their wages. A monthly certification (Federal Hours Certification Report) is sent to exempt and non-exempt staff working on federal projects to ensure their time is charged out appropriately. All employees who work on federal projects verify the allocations of their timesheets, thereby satisfying the effort reporting requirement. All exempt employees (who do not punch in on Kronos) who work on federal projects verify the allocations of their timesheets, thereby satisfying the effort reporting requirement.
Condition: During our testing of 40 MTW employee pays selected for payroll disbursement testing, we noted 4 of the 40 pay did not have adequate time and effort documentation.
Questioned costs: $9,187
Context: We noted that 4 of the 40 pays did not have adequate time and effort documentation. The Authority was unable to provide the Federal Hours Certification Report for these 4 employees.
Cause: Procedures in place regarding quarterly reviews of allocations were not followed.
Effect: The auditor noted instances of noncompliance. Noncompliance results in possible under or over charges to the grant.
Recommendation: We recommend the Authority implements an adequate review process to ensure costs charged to the grant are reasonable, accurate, and properly allocated. We recommend the Authority perform and document this review quarterly at minimum.
Views of responsible officials: There is no disagreement with the audit finding.