Finding Text
2022-001 - Significant Deficiency in Internal Controls over Compliance for Allowable Costs Identification data: U.S. Department of Health and Human Services (HHS) ? Centers for Disease Control and Prevention (CDC), PPHF: Racial and Ethnic Approaches to Community Health Program finance solely by Public Prevention and Health Funds, Assistance Listing No. 93.738, Agreement Identifying No. 18NU58DP006575 and 18NU58DP006575C5. Criteria: The Organization's agreements with the CDC provide for allowable costs to be claimed for eligible program activities, including payroll-related expenses for program and administrative personnel. Condition: The Organization provides for the allocation of program and administrative personnel costs to the program on the basis of time and effort. Inconsistencies and weaknesses in the methodology and documentation supporting such allocations were identified, including the lack of audit trail documentation that connects time study results with allocation determinations utilized within the Organization?s accounting system. Additionally, the Organization does not have a formal method for determining whether allocations based on estimated time and effort reflect actual results. Cause: A breakdown in the Organization?s internal controls over allowable costs did not allow the Organization to maintain complete and thorough documentation to support allocations of salaries costs to the program. Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from maintaining sufficient documentation to support salary cost allocations to the program. Identification of a Repeat Finding: Repeat finding of 2021-001. Recommendation: The Organization should review its system of internal controls over allowable costs, specifically related to allocation methods for payroll-related costs, to determine improvements that can be made to ensure the Organization is maintaining sufficient, complete, and clear documentation to support its allocation methodologies. Additionally, if the Organization utilizes estimates of time and effort in its allocations, a look-back review should be performed to determine appropriateness of such estimates compared to actual results. Time study data, if utilized, should be performed on a routine basis to mitigate risks of inaccuracies. Views of Responsible Officials: The Organization updated their time study evaluations in response to the last single audit to increase the frequency of time study evaluations. However, because of the timing of the last audit being completed in the second quarter of the Organization?s fiscal year, it was found the first quarter of the fiscal year did not reflect the updated procedures. In response to the audit recommendation to increase in the frequency and formality of the time study evaluation and audit trail documentation, the Organization has adopted a more frequent schedule to consistently evaluate staff time through formally documented time study evaluations and will regularly adjust charged salary allocations to ensure a clear connection between time study results and allocation of costs within the Organization?s accounting system.