Finding 497330 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-09-19

AI Summary

  • Core Issue: Payroll expenses for federal awards lacked proper documentation, leading to noncompliance with federal cost principles.
  • Impacted Requirements: 2 CFR part 200 and 45 CFR Part 75 require accurate documentation of personnel expenses and time allocations.
  • Recommended Follow-Up: Implement improved tracking and reporting procedures for time allocations to ensure compliance with federal award terms.

Finding Text

Section III – Federal Award Findings and Questioned Costs Finding: #2023-001 Program Title: Block Grants for Community Mental Health Services, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 93.958, 21.027 Contract Grant Number: HHS000063200002 & HHS00477100002, 2023-02-02-0043 Federal Award Years: September 1, 2022 to August 31, 2024, March 1, 2023 to February 28, 2025 Federal Agency: U.S. Department of Health and Human Services, U.S. Department of Treasury Allowable Costs Type of Finding: Significant Deficiency and Other Noncompliance Criteria: 2 CFR part 200 establishes cost principles for determining costs applicable to Federal Awards and requires costs be adequately documented. In addition, 2 CFR section 200.430 establishes standards for documentation of personnel expenses with the terms and conditions of the federal award. These awards are subject to the requirements set forth in 45 CFR Part 75, which defines the standards for documentation of personnel expenses as charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must 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. Condition: Based on procedures performed, we identified payroll expenditures allocated among federal award programs that were not supported by the time and effort allocation certifications. As a result, verification documentation of payroll allocations across federal award programs was not obtained. Cause: Lack of documentation to support payroll allocations across federal award programs. Effect: Noncompliance with Allowable Costs compliance requirements of the Uniform Guidance and terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend Form Communities improve procedures for tracking and reporting of time allocations across federal award programs to ensure compliance with the compliance requirements and terms and conditions of federal awards. Views of Responsible Officials: Management agrees with the recommendations to improve tracking and reporting of time allocations across federal award programs to conform with the compliance requirements and terms and conditions of federal awards.

Corrective Action Plan

1. Overview Organization Name form communities, Inc. Audit Period January 1 - December 31, 2023 Date of Audit Report 8/26/2024 Prepared By form communities, Inc. Date 8/26/2024 2. Summary of Audit Findings Finding #2023-001 Significant Deficiency and Other Noncompliance 3. Corrective Actions Finding #1: Significant Deficiency and Other Noncompliance ● Description of Issue Based on procedures performed, the auditor identified payroll expenditures allocated among federal award programs that were not supported by the time and effort allocation certifications. As a result, verification documentation of payroll allocations across federal award programs was not obtained. ● Root Cause Analysis Lack of documentation to support payroll allocations across federal award programs. ● Corrective Actions These findings were for 2023, but were not documented in the audit until August 2024. As of January 2024, we’ve already redoubled our efforts to improve time-keeping across programs and funding lines. Today, everyone assigned to projects that require this level of time-keeping must sign-off on a monthly basis asserting that they’re spending at least the minimum amount of time required on relevant project activities. ● Responsible Party The corrective actions are being led by our Program Management Office which ensures that allocation documents are collected for each individual, for each relevant project. ● Timeline The corrective actions have been implemented as of January 2024; however, additional levels of hourly tracking were requested. New payroll software is being implemented to facilitate this level of tracking, shifting from 30 ADP to Proliant. The kick-off meeting for this transition is scheduled for August 28, 2024 with a goal of having a full transition before January 1, 2025. ● Resources Required SignNow: Digital signature collection tool to automate the collection of signatures for all records. Proliant: new timekeeping and payroll software. ● Monitoring and Evaluation PMO should set a goal of receiving 100% of all required allocation documents on a monthly basis. ● Expected Outcome With improved procedures for tracking and reporting of time allocations across federal award programs, we should achieve full compliance with the compliance requirements and terms and conditions of federal awards starting in August 2024. 4. Implementation and Monitoring ● Implementation Plan ○ Starting in January 2024: Consistent collection of monthly allocation plans, and automated signature requests for all relevant individuals ○ Starting in August 2024: Shifting to a new payroll and timekeeping system to increase the level of detail that can be monitored ● Monitoring Plan ○ PMO team will monitor to ensure we have received all required allocation documents ● Responsibility for Monitoring ○ April Jacob from the PMO team 5. Reporting and Documentation ● Reporting: PMO team will create a Slack channel focused on allocations where we will have open tasks to: create allocations, load allocations, and receive notifications when all allocations have been signed. PMO team will be responsible for reporting in that channel when we’ve received 100% of the required allocation documents ● Documentation: The Corrective Action Plan will be stored in the same Slack channel as the allocations, and any relevant questions to the plan can be addressed in that channel, accessible by organizational leadership and PMO team. 6. Conclusion An audit of our 2023 program identified a lack of consistent documentation for 2023. In 2024, we started to archive our monthly allocation plans, and automated the collection of signature documents from our employees so that we have at least two levels of information. As part of our audit process, we determined that it would also make sense to move to a new payroll and timekeeping system, with a goal of full deploying the system by January 1, 2025. The result should be that, for most employees, we have at least 2 levels of awareness for all project involvement. 7. Signatures Name: Eric Estrada Name: Peter McClain Title: Executive Director Title: PMO Lead Date: 08/27/2024 Date: 08/27/2024

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 497331 2023-001
    Significant Deficiency
  • 1073772 2023-001
    Significant Deficiency
  • 1073773 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.958 Block Grants for Community Mental Health Services $486,449
93.516 Affordable Care Act (aca) Public Health Training Centers Program $355,085
93.959 Block Grants for Prevention and Treatment of Substance Abuse $348,215
93.732 Mental and Behavioral Health Education and Training Grants $323,010
21.027 Coronavirus State and Local Fiscal Recovery Funds $240,292