Finding 4874 (2022-004)

Finding 2022-004: Salaries and Wages (Allowable Costs) Criteria: According to 2 CFR Section 200.430(i) 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; 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: During our testwork, we determined that SAMU did not adequately document employee time spent on the Federal program versus other programs. In addition, we noted one instance in which an employee offer letter was not available for examination. Cause: SAMU does not require that all employees complete timesheets documenting time spent on the Federal award versus other awards. Additionally, SAMU does not have effective internal controls in place to ensure that employee salary documentation is retained. Effect or Potential Effect: SAMU could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: Indeterminable. Context: We noted that employees selected for testing did not have completed, detailed timesheets to indicate time spent on the Federal award versus other programs. We also noted instances in which an employee offer letter and employee transition letter were not available for examination. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that SAMU implement formal time tracking policies to require all employees to complete a detailed timesheet in order to track actual time spent on various programs. All timesheets should have evidence of both employee and supervisory approval. Additionally, we recommend that SAMU ensure all salary records for employees are retained.