Finding 528722 (2024-001)

(3)   Findings and Questioned Costs Relating to Federal Awards: Finding 2024 001 Lack of review and approval of Time and Effort Reporting Finding Type: Significant Deficiency Federal Program Name: Immunization Cooperative Agreements Federal Agency: U.S. Department of Health and Human Services ALN # and Program Expenditures: 93.268 ($688,344) Federal Award Year: N/A Questioned Costs: None Compliance Requirement: Activities Allowed or Unallowed Condition Found In performing the monthly time and effort reporting certification and sign-off, management had not established adequate internal controls to ensure the completeness of time and effort certification in accordance with federal regulations, resulting in 4 of 58 (6.9%) submissions missing staff attestations and 2 submissions missing attestation dates. Additionally, for February 2024 time and effort report, while the manager initialed the time and effort report spreadsheet for each attesting employee, their signature was missing to certify their review and approval of the overall monthly submission. Criteria Per 2 CFR 200.303, guidance requires non-Federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing and maintaining adequate controls over the certification of time and effort reporting required for the program. Cause Management did not have appropriate and sufficient review controls in place during the fiscal year to ensure the completeness of time and effort reporting attestation and certification. Possible Asserted Effect Failure to properly review and approve time and effort reports may result in inaccurate time and effort allocations being charged to the program. In this particular case, this did not occur as the employees did record their own hours and were 100% allocated to the specific grant. Repeat Finding No similar finding was reported in prior year audits. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend management review its current process for ensuring time and effort reporting attestation and certifications are properly reviewed and approved by the manager/supervisor before they are submitted to the Grant office and Finance. Views of Responsible Officials FTCH recognizes the observations made by KPMG, and has drafted a Corrective Action response.