Finding Text
Criteria or Specific Requirements Code of Federal Regulations, Subpart E: Cost Principles, section 75.430 Compensation?personal services, paragraph (i)(1) states that: ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed,? and paragraph (i)(1)(viii)I states that: ?Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards but may be used for interim accounting purposes.? In addition, the Ryan White HIV/AIDS Program Treatment Extension Act Part A Grant Contract with Fulton County, GA Board of Commissioners Paragraph 9.15, states that, ?Subrecipient agrees that reimbursements requested under the terms of this Contract shall be made based upon actual expenditures incurred and not upon budgeted amounts.? Condition In performing testwork over the Foundation?s payroll expenditures that were billed to the following grant programs, we noted the following: A. Contract No. 2HA89HA00007-31-00 ? Outpatient Ambulatory Health Service Program Of the (12) payroll expenditures tested, we noted that: o Five (5) expenditures were supported by timesheets that did not indicate any program hours worked. o One (1) expenditure was supported by a timesheet showing lesser hours than the hours billed to the grantor. B. Contract No CODTPI/CODUD ? Housing Opportunities for People With AIDS Program Seven (7) out of eleven (11) expenditures tested were supported by timesheets that did not indicate any program hours worked. The above discrepancies were due to the fact that the amounts billed to the grantor were based on budget estimates rather than actual expenditures. We also noted that the total actual expenditures initially coded under the above 2 programs in the general ledger were lower than the respective total amounts billed for the fiscal year. This was attributed to the fact that some expenditures were classified under an unassigned category in the general ledger since the Foundation?s process of determining their correct program codes is ongoing. Upon further discussion with management, we were informed that the total actual expenditures for each program, when taking into consideration the expenditures classified under the unassigned category, exceeds the respective total amounts billed for the programs. Questioned Costs (Expenditures tested) A. $18,911 B. $22,433 Cause and Effect Discrepancies between the claims for reimbursements for payroll expenditures and supporting employee timesheets arise because the Foundation submits its claims for payroll reimbursements based on predetermined percentages for interim accounting purposes, rather than actual employee hours worked under the program. A reconciliation process is performed at the end of the fiscal year to determine the actual program expenditures. However, this reconciliation process was ongoing during the audit. Recommendation We recommend that the Foundation revisit its existing process and procedures in tracking and billing federal expenditures. A process should be in place whereby payroll expenditures charged to the federal programs are 1) accurately determined based on the actual hours worked by the employees on the respective programs; 2) adequately supported by timesheets and other source documentation; and 3) formally documented to easily agree and/or reconcile to the supporting documentation. This is to maintain transparency and accountability of federal funds and ensure compliance with federal requirements. Additionally, a system should be implemented to ensure that tracking of costs by fund is done in a timely manner. Views of Responsible Officials and Planned Corrective Actions The timesheets did not reflect the correct hours charged to the program. After discussions with program management, it was discovered that correct communication to staff had not been completed regarding proper program and grant payroll coding for work done on the program. This has been corrected. The Foundation?s contract administrative staff is working more closely with program staff to ensure for each payroll that the time worked on programs is properly reflected on timesheets that are approved by employees and managers. Necessary changes are communicated between program and contract administrative staff to ensure that timesheets reflect work hours properly. Personnel responsible for implementation: Steven Hartman Position of responsible personnel: Associate Director, Contract Accounting Date of Implementation: August 31, 2023