Finding Text
U.S. Department of Justice, passed through Missouri Department of Social Services
Crime Victim Assistance - 16.575
Multiple Awards and Award Years
Criteria or Specific Requirement – Allowable Costs/Cost Principles
Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)).
The Crime Victim Assistance award document also requires "daily time and activity records for all staff funded by this grant project that document the services and grant projects that the staff person worked on and the time spent providing the services or programs."
Condition – During our test work over the Crime Victim Assistance grant, we noted the Organization did not have time and activity records with sufficient detail per federal regulations and Crime Victim Assistance award document to support its compensation and fringe benefit expenses.
Questioned Costs – Total questioned costs of $27,051 were identified as a result of lack of proper documentation to support the charge and allocation to the grant.
Context – We selected a sample of 60 charges to the Crime Victim Assistance grants of which 59 were salaries and benefits expenditures with a value of $35,957. Within our sample, we noted 47 of the selections did not have proper documentation to support the charge and allocation to the grant (e.g ., daily time and activity records, etc.). These 47 selections had a value of $27,051. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the grant in the audit period totaled $1,378,704 and represented 94% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Based on testing completed, the Organization did not have sufficient procedures to record and verify employees time and activity throughout fiscal year 2022.
Cause – Management indicated that this was attributed to a misunderstanding of the requirements of the time and activity reports. This issue was brought to the attention of management in the third quarter of fiscal year 2022. Management implemented a time and activity tracking method that tracks employees' time and effort on a daily basis in the fourth quarter of fiscal year 2022.
Identification as a Repeat Finding – Repeat finding, see 2021-004 and 2020-004.
Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations and Crime Victim Assistance award documents. We also recommend employees and their supervisors are provided training on the requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the
stated finding and has implemented a corrective action plan.