FAC Explorer

Finding 499777 (2023-001)

Material Weakness
Requirement
A
Questioned Costs
$1
Year
2023
Accepted
2024-09-30
Audit: 322621
Organization: Columbus Neighborhood Health Center, Inc. Dba Primaryone Health (OH)
Auditor: Clark Schaefer Hackett

AI Summary

  • Core Issue: Lack of proper time and effort reporting for payroll costs charged to federal awards.
  • Impacted Requirements: Compliance with 2 CFR 200.430, which mandates accurate tracking of personnel costs.
  • Recommended Follow-Up: Implement new policies to ensure time and effort charges accurately reflect actual work performed.

Finding Text

Federal Award Findings and Questioned Costs Finding No. 2023-001: Allowable Cost (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.224 Health Center Program Cluster ALN 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to the work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.224 Health Center Program Cluster and 40 payroll costs charged to ALN 93.354 Public Health Emergency Response: Cooperative agreement for Emergency Response: Public Health Crisis Response. Time and effort reporting could not be located for any of the charges which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization changed payroll systems during the year and did not implement procedures to properly track time and effort under the new system. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: Unknown Repeat Finding: No Recommendation: Management should establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allowable costs which includes ensuring time and effort charges are based on records that accurately reflect the work performed. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.

Corrective Action Plan

Columbus Neighborhood Health Center, Inc. dba PrimaryOne Health Corrective Action Plan Year Ended December 31, 2023 Contact Information: Charleta B. Tavares, Chief Executive Officer 614. 859. 1946 ctavares@primaryonehealth.org Audit period: January 1, 2023 – December 31, 2023 Finding 2023-001 – Allowable Costs (Time and Effort) Recommendation: Management should establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allowable costs which includes ensuring time and effort charges are based on records that accurately reflect the work performed. Action planned/take in response to finding: 1. Implementation of Time and Effort Reporting System: The organization has begun to establish and implement a robust time and effort reporting system in compliance with 2 CFR 200.430. This system will: a. Accurately reflect the distribution of employee time across different federal grants. b. Track employee hours worked, allocate wages based on grant activities, and ensure the proper alignment of salaries to the work performed. c. Provide documentation supporting time allocation between different federal and non-federal activities. 2. Training for Payroll and Grants Management Staff: All payroll, human resources, and finance staff will undergo mandatory training on: a. Time and effort reporting requirements under federal guidelines. b. The correct procedures for allocating wages to federal grants, including compliance with Uniform Guidance (2 CFR 200). 3. Updating Policies and Procedures: The organization will update internal policies to reflect compliance with the Uniform Guidance, particularly regarding payroll documentation and time and effort allocation. This will include: a. Establishing written procedures on tracking employee work hours and effort reporting. b. Implementing monthly or quarterly reviews to ensure payroll costs are appropriately charged to federal awards. 4. Periodic Internal Audits: The organization will conduct periodic internal audits to ensure continued compliance with federal requirements, especially as it relates to payroll and time tracking. Any discrepancies will be promptly corrected to avoid future findings. Planned completion date for corrective action plan: December 31, 2024

Categories

Questioned Costs Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 499778 2023-001
    Material Weakness
  • 1076219 2023-001
    Material Weakness
  • 1076220 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.224 Community Health Centers $7.52M
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $1.01M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $384,146
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $259,941
93.994 Maternal and Child Health Services Block Grant to the States $132,665
93.940 Hiv Prevention Activities Health Department Based $89,370
93.926 Healthy Start Initiative $79,478
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $79,000
93.137 Community Programs to Improve Minority Health Grant Program $25,245
93.914 Hiv Emergency Relief Project Grants $23,001
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $16,000