Finding Text
Finding 2023-002 Salaries and Wages (Allowable Costs)
Criteria or Specific Requirement: According to 2 CFR Section 200.430(i), charges to Federal grants for salaries and wages must be based on records that accurately reflect the work performed and the 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;
vi. [Reserved]
vii. 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.
viii. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”
Condition: NRGI has a timekeeping system in place that provides for employees to record hours worked to specific cost objectives, including to U.S. Government grants. However, we noted that in several cases, the allocation amounts as per the timekeeping system were different from the amounts ultimately recorded within NRGI's general ledger. While the differences were not significant, these discrepancies indicate a deficiency in the internal controls around recording of salary expenditures to projects.
Cause: The primary cause appears to be human error, and the result of manual recordkeeping.
Effect or Potential Effect: Salary expenditures that are not charged in accordance with the standards referenced above may be questioned or disallowed by the donor.
Questioned Costs: Undetermined.
Context: This is a condition identified per review of NRGI's compliance with the specified requirements using a statistically valid sample.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend that management revisit its procedures for transferring data from the timekeeping system to the general ledger and implement proper internal controls to ensure that the amounts of salary expenditures charged to grants in the general ledger reconcile to the amounts calculated by the timekeeping system.