Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster, Temporary Assistance for Needy Families
Federal Assistance Listing Number: 93.224, 93.527, 93.558
Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria:
According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget's Uniform Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: (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.
Condition/Context:
In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance testing, we noted that the time and effort attestations for all employees were not completed at all during fiscal year 2023. Salaries and related costs were charged to the grants based on budgeted estimates.
Cause:
Procedures and controls were not put in place to ensure actual time spent was properly charged to the programs.
Effect or Potential Effect:
The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant.
Questioned Costs:
None
Identification as a Repeat Finding
Yes - See 2022-003
Auditor's Recommendation:
The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely.
Views of Responsible Officials:
The Center will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.