Finding 517887 (2023-003)

45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods. The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays. In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation. 1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity. 2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed. 3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator. 4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle. Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours. The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023: • Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period. • Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period. • One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not. • Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed. Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool. The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.