Finding 539534 (2024-001)

-
Requirement
A
Questioned Costs
$1
Year
2024
Accepted
2025-03-28

AI Summary

  • Core Issue: Errors in employee time allocation and salary rates led to noncompliance with federal program requirements for the Small Business Administration Microloan Program.
  • Impacted Requirements: The Organization failed to ensure payroll costs were accurately supported by time records and salary limits, resulting in questioned costs exceeding $63,740.
  • Recommended Follow-Up: Strengthen internal controls by regularly reconciling payroll charges to actual time records and ensuring proper review and approval of documentation.

Finding Text

Reference Number: 2024-001 Finding: Finding Type: Immaterial noncompliance with major program requirements Title and CFDA Number of Federal Program: 59.046 – Small Business Administration Microloan Program Finding Resolution Status: In review. Information on Universe and Population Size: Salaries and wages pursuant to approved budget for the period July 1, 2023 to June 30, 2024. Salaries and wages per approved budget is $1,885,028. Sample Size Information: A sample of 20 allocations of salaries and wages allocated to the program during the budget period were selected for testing compliance, including to approved time allocations within the payroll processor and as compared to the Executive Level II Salary max amounts in effect during the budget period. Identification of Repeat Finding and Finding Reference Number: N/A Criteria: The Organization is required to submit an award budget for approval, including direct costs to be allocated to the award. The Organization is then required to submit a schedule of actual allocated costs incurred for reimbursement. Statement of Condition: During our testing of allocated salaries and wages, we identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Cause: The Organization did not have adequate procedures in place to ensure that payroll costs were supported by accurate time and rates reporting. Certain allocations were made subsequent to the approved budget amounts, however support was not substantiated for those allocations. Effect or Potential Effect: Salaries and wages charged to the program included unsupported amounts, resulting in projected questioned costs of $63,740. When the actual errors in the sample tested were projected across the population, the potential error exceeds $25,000, which requires reporting under 2 CFR 200.516(a). However, the total projected questioned costs were not material to the program. Auditor Noncompliance Code: A – Activities allowed or unallowed Reporting Views of Responsible Officials: Management agrees with the noncompliance with no sanctions imposed conclusion. Context: No additional context identified by the Organization which is not otherwise presented herein. Recommendation: The Organization should strengthen internal controls over payroll cost allocations, including regular reconciliation of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management should complete regular reconciliations of payroll charges to actual time records and rates. Time and rate documentation should be properly reviewed and approved. Response Indicator: Agree Completion Date: In process. Response: Management acknowledges noncompliance in the current fiscal year and is reviewing its internal controls over payroll cost allocations. Questioned Costs: $63,740

Corrective Action Plan

Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Planned Corrective Action: ECDI will put additional steps in place in Payroll Review process to ensure reconciliation of payroll charges to actual time records and rates. The organization will modify it's calculations to ensure that pay rates are reflective of the timeframe in question (not for periods before or after). ECDI will update its calculations to include thresholds for Executive pay so they are not entered in excess of approved rates. The company is also exploring technology enhancements so that information from ECDl's Payroll system flows directly into ECDl's Accounting system to limit the chance of errors during extraction from Payroll system and uploading into Accounting system. Contact Person Responsible for Corrective Action: Brian Barrett and Hudu Ahmed. Completion Date: In process

Categories

Questioned Costs Allowable Costs / Cost Principles Cash Management Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
59.046 Microloan Program $7.33M
21.020 Community Development Financial Institutions Program $1.25M
93.570 Community Services Block Grant Discretionary Awards $563,085
10.870 Rural Microentrepreneur Assistance Program $554,908
59.043 Women's Business Ownership Assistance $537,500
23.001 Appalachian Regional Development (see Individual Appalachian Programs) $442,401
59.050 Prime Technical Assistance $384,065
14.218 Community Development Block Grants/entitlement Grants $291,302
93.576 Refugee and Entrant Assistance Discretionary Grants $204,332