Finding 481040 (2023-002)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-08-13
Audit: 317176
Organization: Colorado Poverty Law Project (CO)

AI Summary

  • Core Issue: Lack of documented review for timecards before reimbursement submission.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 regarding internal controls over federal awards.
  • Recommended Follow-Up: Implement a policy for timecard reviews prior to submission; corrective actions are already in progress.

Finding Text

Finding 2023-002 Timesheet Review Information on the Federal Program: Assistance Listing Number 21.027—U.S Department of Treasury, Coronavirus State and Local Fiscal Recovery Funds. Compliance Requirements: Allowable Cost and Activities Type of Finding: Significant Deficiency. Criteria: 2 CFR 200.303 requires all non-federal entities to 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: In our testing of 25 time cards, we noted that there is no documented evidence that time cards are being reviewed prior to being submitted for reimbursement. No instances of non-compliance, or errors, were noted in this testing. Cause: Colorado Poverty Law doesn’t have policies that require timecards be reviewed prior to submission. Effect or Potential Effect: Time submitted for reimbursement could be inaccurate. Questioned Costs: None. Context: We tested 25 time cards to ensure amounts charged to the grant were adequately supported. This covered $61,206 of the $1,315,667 of salaries submitted for reimbursement. In all 25 instances, the time card allocations supported the amount charged to the grant, but none of these instances contained any evidence the time card was reviewed. Recommendation: We recommend that Colorado Poverty Law adopt a policy to review timesheets prior to submission for reimbursement. Views of Responsible Official: We agree with this finding, and corrective action was taken in May 2024. The Executive Director along with the Operations Manager review all time entries at each month-end to ensure staff time is accurately recorded and appropriately allocated to each funding source prior to submitting to the grantor for reimbursement.

Corrective Action Plan

We agree with this finding, and corrective action was taken in May 2024. The Executive Director along with the Operations Manager review all time entries at each month-end to ensure staff time is accurately recorded and appropriately allocated to each funding source prior to submitting to the grantor for reimbursement.

Categories

Allowable Costs / Cost Principles Cash Management Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1057482 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $173,780
21.019 Coronavirus Relief Fund $76,239