Finding Text
Federal Program Information: WIOA Pilots, Demonstrations, and Research Projects (ALN#: 17.261) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles ? 2 CFR 200 Subpart E- Cost Principles ? 200.430 Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in ? 200.431. 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 established 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, when applicable. Condition: An instance was identified where BGCA allocated costs in excess of actual services rendered. Cause: Insufficient internal controls and administrative oversight with respect to payroll and fringe expenditure allocation based on approved hours worked on federal grant. Effect: BGCA was not in compliance with allowable cost requirements. Questioned Costs: Amount was below reportable threshold. Context: For 1 of 5 employees selected for testing, payroll expenditures and fringe benefits were allocated to the grant in excess of actual hours worked. Consequently, the overallocated expenditures were submitted and approved for reimbursement in excess of actual expenses incurred. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend BGCA enhance its internal controls and policies and procedures over allocation of payroll and fringe expenditures to federal grants based on actual hours worked. Views of Responsible Officials and Planned Corrective Actions: Management will implement a new quality review process to ensure that correct default fund codes are assigned to staff for the DOL WPY grant. In addition, management will implement a complete oversight review of all grant time charges in advance of the execution of a drawdown of DOL funds.