Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non‐Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services.
Audit Recommendation: We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job‐costing system implemented.
Auditee Response: The Organization believes that leadership/personnel turnover, along with outsourced financial management, allowed paychecks to be approved without the proper approval flow. We have ensured documenation is downloaded/kept each pay period to ensure such documentation is not lost when a change in service provider is made. Corrective Action Plan: UICSL has moved away from its prior payroll processor to better account for these labor allocations and grant classifications. In our FY23 audit, we requested data from our prior processor multiple times. They were unable to provide some of the reports and data which was purged from their system. Our new payroll processor ensures employees' time is allocated to each grant program and there is a designated reporting funcation allowing us to reviews what is assigned. UICSL also has better defined leadership and directors for each division so there are clearly defined approvers and supervisors for each purchase and transaction.
Person Responsible: Matt Poss, Executive Director and Eva Leyer, Human Resources Manager
Timeline: UICSL transitioned to a new payroll processor at the end of 2023 and Leadership was designated and assigned for 2024.