Finding 577256 (2022-004)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-10-27

AI Summary

  • Core Issue: NGA Center lacks proper internal controls over payroll processes, leading to inaccuracies in time reporting and expense calculations.
  • Impacted Requirements: Compliance with 2 CFR Section 200.430 on compensation and documentation standards is not being met, risking incorrect charges to Federal programs.
  • Recommended Follow-Up: Enhance internal controls by separating the preparation and review of payroll and benefits, and ensure accurate documentation for timesheets and project codes.

Finding Text

2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding.   Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 809 2022-004
    Material Weakness
  • 810 2022-004
    Material Weakness
  • 811 2022-004
    Material Weakness
  • 812 2022-004
    Material Weakness
  • 813 2022-004
    Material Weakness
  • 814 2022-004
    Material Weakness
  • 815 2022-004
    Material Weakness
  • 816 2022-004
    Material Weakness
  • 817 2022-005
    Material Weakness
  • 818 2022-005
    Material Weakness
  • 819 2022-005
    Material Weakness
  • 820 2022-005
    Material Weakness
  • 821 2022-005
    Material Weakness
  • 822 2022-005
    Material Weakness
  • 823 2022-005
    Material Weakness
  • 824 2022-005
    Material Weakness
  • 825 2022-006
    Material Weakness
  • 826 2022-006
    Material Weakness
  • 827 2022-006
    Material Weakness
  • 828 2022-006
    Material Weakness
  • 829 2022-006
    Material Weakness
  • 830 2022-006
    Material Weakness
  • 831 2022-006
    Material Weakness
  • 832 2022-006
    Material Weakness
  • 577251 2022-004
    Material Weakness
  • 577252 2022-004
    Material Weakness
  • 577253 2022-004
    Material Weakness
  • 577254 2022-004
    Material Weakness
  • 577255 2022-004
    Material Weakness
  • 577257 2022-004
    Material Weakness
  • 577258 2022-004
    Material Weakness
  • 577259 2022-005
    Material Weakness
  • 577260 2022-005
    Material Weakness
  • 577261 2022-005
    Material Weakness
  • 577262 2022-005
    Material Weakness
  • 577263 2022-005
    Material Weakness
  • 577264 2022-005
    Material Weakness
  • 577265 2022-005
    Material Weakness
  • 577266 2022-005
    Material Weakness
  • 577267 2022-006
    Material Weakness
  • 577268 2022-006
    Material Weakness
  • 577269 2022-006
    Material Weakness
  • 577270 2022-006
    Material Weakness
  • 577271 2022-006
    Material Weakness
  • 577272 2022-006
    Material Weakness
  • 577273 2022-006
    Material Weakness
  • 577274 2022-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.528 National Forum for State and Territorial Chief Executives: Hhs Oa, Yr 10 Adn Yr 11, National Forum $566,329
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health:suicide Opioids Misuse Prevention $520,834
93.421 Strengthening Public Health Systems and Services Through Lowering Opioid Overdose Risk for Justice-Involved Populations; Building State and Institutional Capacity $326,942
81.214 Environmental Monitoring/cleanup, Cultural and Resource Mgmt., Emergency Response Research, Outreach, Technical Analysis $233,528
81.122 Electricity Delivery and Energy Reliability, Research, Development and Analysis:programmatic Collaboration and Coordination with Governors, Cr $212,894
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health: Diabetes $189,298
93.421 Strengthening Public Health Systems and Services Through Informing State Leaders on Effective Policies and Systems Strategies for Enhancing Infectious Disease Surveillance $188,702
81.122 Electricity Research, Development and Analysis:programmatic Collaboration and Coordination with State Governors, Oe $160,022
97.132 Financial Assistance for Countering Violent Extremism $150,829
81.122 Electricity Research, Development and Analysis: Infrastructure Security and Energy Restoration (iser) $148,975
81.122 Electricity Research, Development and Analysis: Transmission Permitting and Technical Assistance (tpta) $137,330
12.615 Research and Technical Assistance $134,060
16.738 Edward Byrne Memorial Justice Assistance Grant Program $126,222
97.007 Homeland Security Preparedness Technical Assistance Program $111,917
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health:engaging Governors to Strengthen Vaccines Confidence $84,310
16.838 Comprehensive Opioid Abuse Site-Based Program $70,422
81.121 Office of Nuclear Energy Coordination with State Governors for Office of Nuclear Energy $67,120
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health: Public Health Emergency Preparedness and Response $62,017
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health: Engaging State Leadership and Entities to Address Unintentional Injury Topics $57,638
17.U01 Expanding Community College Apprenticeships $53,127
17.268 H-1b Job Training Grants: Usdol Eta American Apprenticeship Initiative Recipient $12,552
16.827 Data Lead Governance $9,159
16.321 Crime Victim Assistance/discretionary Grants Continuation $793