Finding Text
2024-005 Controls over Payroll Allowable Costs - Significant Deficiency in Internal Control over Compliance Criteria and Condition: According to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), section 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for changes to Federal awards, but may be used for interim accounting purposes, provided that the system for establishing the estimates procudes reasonable approximations of the activity actually performed; significant changes in the corresponding work activity are identified and entered into the records in a timely manner; and the non-Federal entity's system of internal controls includes processes to review after-the-fact interimcharges based on budget estimates. Admin and support personnel salaries or wages for the Twenty-First Century Community Learning Centers program were based on budget estimates as documented in the approved grant budget for personnel costs and fringe benefit costs. However, there was non evidence of an after-the-fact review to determine that the distribution accurately reflected the work performed by the employee. Cause: For one month selected for testing the Twenty-First Century Community Learning Centers program the labor allocation reports provided did not match what was billed per the billing tracker reports. Timesheets from January through September did not have approvals available for review. Employees charged to the grant through a budgeted percentage had no after-the-fact review. Effect and Context: When adequate support is not obtained and used to support the amount charged to the federal program or supported by an after-the-fact review, there is a risk that unsupported or inaccurate costs are being charged to the federal program. Questioned Costs: Payroll costs charged to the awards totaled $118,969. Recommendation: We recommend proper control activities should be implemented to allow for a consistent, accurate, and allowable method to support distribution of personnel charges to federal programs. If management elects to continue to allocate personnel charged based on a budget estimate, the after-the-fact review should be properly documented. Views of responsible officials and planned corrective actions: YMCA management will implement a process to perform timely review of salary expense charged to federal awards and retain records by pay period as support for expenditures charged to federal awards and retain records by pay period as support for expenditures charged to federal awards.