Finding 522144 (2024-003)

Significant Deficiency Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-02-05
Audit: 341351
Organization: United Way of Greater Cleveland (OH)
Auditor: Bdo USA LLP

AI Summary

  • Core Issue: The organization failed to properly document employee hours worked for the Title XX federal program, leading to unsupported payroll reporting.
  • Impacted Requirements: Compliance with CFR 200.329(b) regarding financial data and performance goals was not met, risking potential noncompliance and funding loss.
  • Recommended Follow-Up: Implement a monthly analysis to ensure all hours billed are supported by timecards and reconcile payroll reports before invoicing federal agencies.

Finding Text

Information on Federal Program:United States Department of Health and Human Services Assistance Listing Number: 93.667Assistance Listing Name: Social Services Block Grant Pass-Through Awards under the Uniform Guidance Requirements: Pass-Through Entity Award Number Award Period Ohio Department of Job and Family Services HS157289 January 1, 2023 - December 31, 2023 and January 1, 2024 - December 31, 2024Criteria: CFR 200.329(b) states that when reporting program performance, the recipient or subrecipient must relate financial data and project or program accomplishments to the performance goals and objectives of the federal award. Also, the recipient or subrecipient must provide cost information to demonstrate cost-effective practices (for example, through unit cost data) when required by the terms and conditions of the federal award.Condition: During our testing of reporting, we test selected two reports for testing and noted two exceptions in the ability of management to support payroll reported to for the Title XX federal program. The Organization did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. The Organization inadvertently overallocated the time allocation for the program; however, total costs incurred by the Organization after exclusion of the overallocation were not in excess of the amounts funded by the program.Cause: The Organization did not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged to federal programs.Effect or Potential Effect: An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards can lead to noncompliance with law and regulations and possible loss of funding for the related program.Questioned Costs: None. Context: The Organization collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure did not exist at the time to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing.Repeat Finding: This is a repeat finding.Recommendation: We recommend that the Organization continues their new policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation to support costs reported to the program. We further recommend that management continue to review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce.Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and the recommendation.

Corrective Action Plan

UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Management’s Corrective Action Plan: UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management Reporting

Other Findings in this Audit

  • 522142 2024-002
    Significant Deficiency Repeat
  • 522143 2024-002
    Significant Deficiency Repeat
  • 522145 2024-003
    Significant Deficiency Repeat
  • 1098584 2024-002
    Significant Deficiency Repeat
  • 1098585 2024-002
    Significant Deficiency Repeat
  • 1098586 2024-003
    Significant Deficiency Repeat
  • 1098587 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $257,818
93.667 Social Services Block Grant $251,460
93.558 Temporary Assistance for Needy Families $195,211
93.052 National Family Caregiver Support, Title Iii, Part E $187,802
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $181,366
14.267 Continuum of Care Program $133,888
93.493 Congressional Directives $96,725
97.024 Emergency Food and Shelter National Board Program $6,525
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $2,884