Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements
Federal Assistance Listing Number: 93.224, 93.527, 93.268
Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria:
The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis.
Condition/Context:
In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit.
Cause:
Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors.
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
No
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:
Family First Health 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.