Finding 576234 (2024-003)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-09-12
Audit: 366160
Organization: Opening Doors, Inc. (CA)

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance related to payroll, specifically the lack of documentation for wage rate changes.
  • Impacted Requirements: Costs must be necessary and reasonable under 2 CFR 200.403(a), and unapproved wage increases could lead to questioned costs totaling over $553,000.
  • Recommended Follow-Up: Strengthen policies to ensure all wage rate changes have documented approvals to prevent future compliance issues.

Finding Text

Federal Agency: U.S. Department of Health & Human Services Federal Program Name: Refugee and Entrant Assistance Voluntary Agency Programs Assistance Listing Number: 93.576 Federal Award Identification Number and Year: Various, see below Pass-Through Agency: Various, see below Pass-Through Number: Various, see below Award Period: Various, see below Compliance Requirement Affected: Allowable Costs & Activities (Payroll) Direct Agency Direct Award number Award Period Pass Through Entity (or) Pass Through Number U.S. Department of Health & Human Services (Direct) 90RG0243-01-00 10/1/2023-9/30/2024 90RG0225-01-00 10/1/2022-9/29/2025 90ZI0174-01-00 9/30/2023-09/29/2027 Passed through California Department of Social Services N/A 10/1/2023-9/30/2024 Passed through Los Rios Community College District N/A 9/30/2022-9/29/2025 Passed through Church World Services CWS-2024-04-015 10/1/2023-9/30/2024 CWS-2024-10-017 10/1/2024-9/30/2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Condition: During our single audit procedures of allowable costs, six employees had pay rates that could not be substantiated via evidence of approval on an approved wage rate change form. Questioned Costs: Known $14,112 Likely $553,607 Context: A nonstatistical sample of 16 out > 250 pay periods were selected for testing for the Refugee and Entrant Assistance Voluntary Agency Programs program. The condition noted above was identified during our procedures over ODI's Allowable Costs & Activities (payroll). Effect: ODI did not retain documentation of wage rate change approvals, which could result in unapproved increases in wage rate changes being charged to the grant. Cause: ODI has a control designed to approve wage rate changes. However, documentation of approval could not be located. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that ODI strengthen its current policies and procedures to ensure that documentation is retained for approval of all wage rate changes. Management’s Views: Management takes responsibility for the finding and believes that in future years, they will be able to implement proper controls to mitigate this finding.

Corrective Action Plan

Auditor's Recommendation: Strengthen policies and procedures to ensure proper authorization and documentation of payroll changes. Management Response: While ODI does not disagree with the audit finding, the Agency does clarify the context of the finding. ODI has a policy for setting, processing, and approving staff wage rates as follows: Sr. HR Manager or Payroll Assistant process new hires and sets them up in the timekeeping system (NOVAtime). Any salary changes are also processed by DHR (may also be processed by supervisor) on a change status form and approved by CEO. The auditors performed tests to determine if the CEO approved the change status form. As mentioned in the audit finding, of the audit sample of employees tested in the 16 pay periods from more than 250 pay periods, six employees did not have their change of status forms signed by the CEO. Audit requirements for federal awards require the auditors to assign a value to specific instances of noncompliance as “known questioned costs”. The known questioned costs for this finding are $14,112 and are comprised of the transactions the auditors tested for allocated wages of the six employees to specific grants. The auditors further calculate “likely questioned costs” by extrapolating the auditor’s sample across the entire population from which the sample is drawn and is $553,607. Is it important to note that the “known questioned costs” and the “likely questioned costs” are not calculations of errors or misstatement in the financial statements. All six employees' pay rates were processed correctly despite missing CEO signatures on the change status forms. Corrective Action: -Conduct comprehensive internal audit of all current staff to verify proper processing and CEO approval of change status forms -Implement dual-filing system: approved forms will be maintained in both personnel folders and financial accounting folders to verify that approved pay rates are used when charging labor costs to any grant. Responsible Personnel: Karen Dickson, Sr. Finance Director; Lisa Tucker, Sr. HR Manager Implementation Date: Immediate implementation

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 576233 2024-002
    Material Weakness
  • 576235 2024-002
    Material Weakness
  • 576236 2024-003
    Material Weakness
  • 576237 2024-002
    Material Weakness
  • 576238 2024-003
    Material Weakness
  • 576239 2024-002
    Material Weakness
  • 576240 2024-003
    Material Weakness
  • 576241 2024-002
    Material Weakness
  • 576242 2024-003
    Material Weakness
  • 576243 2024-002
    Material Weakness
  • 576244 2024-003
    Material Weakness
  • 576245 2024-004
    Significant Deficiency
  • 1152675 2024-002
    Material Weakness
  • 1152676 2024-003
    Material Weakness
  • 1152677 2024-002
    Material Weakness
  • 1152678 2024-003
    Material Weakness
  • 1152679 2024-002
    Material Weakness
  • 1152680 2024-003
    Material Weakness
  • 1152681 2024-002
    Material Weakness
  • 1152682 2024-003
    Material Weakness
  • 1152683 2024-002
    Material Weakness
  • 1152684 2024-003
    Material Weakness
  • 1152685 2024-002
    Material Weakness
  • 1152686 2024-003
    Material Weakness
  • 1152687 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.510 U.s. Refugee Admissions Program $4.96M
93.576 Refugee and Entrant Assistance Discretionary Grants $1.98M
14.267 Continuum of Care Program $613,649
93.569 Community Services Block Grant $74,961
59.046 Microloan Program $64,444
21.020 Community Development Financial Institutions Program $16,108