FAC Explorer

Finding 627578 (2022-002)

Significant Deficiency Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-03-30
Audit: 41338
Organization: Kennesaw State University Research and Service Foundation, Inc. (GA)
Auditor: Cherry Bekaert LLP

AI Summary

  • Core Issue: Incomplete Time and Effort Certifications for federal awards, leading to potential non-compliance with federal regulations.
  • Impacted Requirements: The lack of proper certifications violates OMB's Uniform Guidance, risking unallowable expenditures on federal awards.
  • Recommended Follow-Up: Implement a system to ensure timely completion of certifications based on pay periods, and provide annual training for relevant staff.

Finding Text

Finding 2022-002 Federal Agency: Various Federal Program: Research and Development Cluster CFDA: Various Compliance Requirement: Allowable Costs ? Incomplete Time and Effort Certifications Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes CRITERIA: The Office and Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (?Uniform Guidance?) establishes principles and standards for determining costs for federal awards carried out through grants, contracts, and other agreements. To be allowable under federal awards, expenditures must be allocable, reasonable, and supported by adequate documentation. Section 200.430 of Uniform Guidance requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (a) the system for establishing the estimates produces reasonable approximations of the activity actually performed; (b) significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner; and (c) the non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. CONDITION: To meet the requirements of the Uniform Guidance for time and effort reporting, the Foundation utilizes an after-the-fact effort reporting system to certify that salaries charged, or cost shared, to Federal awards are reasonable and consistent with the work performed. The individual?s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended is then certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator, at the end of each semester. The Grants Office manually creates time and effort reports each semester. These effort reports are by Federal award and note all the employees who had payroll charged or cost shared to the project, the percentage of each employee?s total payroll charged or cost shared to the project, as well as the percentage of each employee?s total payroll charged to other projects or activities so that 100 percent of each employee?s effort is reported. The Principal Investigator for each Federal award is required to sign the Time and Effort reports to certify the reasonableness of the estimated total work effort for the period covered by the report. During our testing of the Research and Development Cluster, we sampled 40 expenditures. The sample was not intended to be and was not statistically valid. These 40 expenditures represented charges made on 20 federal awards. Payroll charges for 29 employees were selected for 9 of these federal awards. Our review of the Time and Effort Certifications resulted in the following: -Certifications were not completed for four (4) employees who had charges on two (2) projects in our sample. - For all the Time and Effort Certifications reviewed, the percentages of effort being certified were calculated based on the date the payroll charges were made or adjusted. If adjustments from a prior period were posted to a subsequent period, the percentage of effort for the period being certified were distorted and did not truly reflect the percentage of effort for the current term being certified. QUESTION COSTS: $2,100 ? calculated as the total payroll of the sampled payroll expenditures for which no Time and Effort Certification was completed. CAUSE: The Foundation does not have a system of process and controls in place to ensure all payroll certifications are completed. EFFECTS: Effort reporting is a federal compliance requirement. Lack of time and effort certifications could result in expenditures of federal awards for unallowable purposes. RECOMMENDATIONS: We recommend all payroll charges and adjustments to payroll charges be assigned a pay period. Time and Effort Certifications should include data based on these pay periods, and not the general ledger posting period. We also recommend the Time and Effort Certifications be prepared for each employee who had time charged to any federal program or cost shared to any federal program, rather than prepared for each federal award. The Foundation should then implement policies and control procedures to ensure time and effort certifications are completed in a timely manner. These policies should include annual training of the Grants Office as well as Principal Investigators and Department Administrators involved in federal awards. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: See attached management?s corrective action plan.

Categories

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 51125 2022-002
    Significant Deficiency Repeat
  • 51126 2022-002
    Significant Deficiency Repeat
  • 51127 2022-002
    Significant Deficiency Repeat
  • 51128 2022-002
    Significant Deficiency Repeat
  • 51129 2022-002
    Significant Deficiency Repeat
  • 51130 2022-002
    Significant Deficiency Repeat
  • 51131 2022-002
    Significant Deficiency Repeat
  • 51132 2022-002
    Significant Deficiency Repeat
  • 51133 2022-002
    Significant Deficiency Repeat
  • 51134 2022-002
    Significant Deficiency Repeat
  • 51135 2022-002
    Significant Deficiency Repeat
  • 51136 2022-002
    Significant Deficiency Repeat
  • 51137 2022-002
    Significant Deficiency Repeat
  • 51138 2022-002
    Significant Deficiency Repeat
  • 51139 2022-002
    Significant Deficiency Repeat
  • 51140 2022-002
    Significant Deficiency Repeat
  • 51141 2022-002
    Significant Deficiency Repeat
  • 51142 2022-002
    Significant Deficiency Repeat
  • 51143 2022-002
    Significant Deficiency Repeat
  • 51144 2022-002
    Significant Deficiency Repeat
  • 51145 2022-002
    Significant Deficiency Repeat
  • 51146 2022-002
    Significant Deficiency Repeat
  • 51147 2022-002
    Significant Deficiency Repeat
  • 51148 2022-002
    Significant Deficiency Repeat
  • 51149 2022-002
    Significant Deficiency Repeat
  • 51150 2022-002
    Significant Deficiency Repeat
  • 51151 2022-002
    Significant Deficiency Repeat
  • 51152 2022-002
    Significant Deficiency Repeat
  • 51153 2022-002
    Significant Deficiency Repeat
  • 51154 2022-002
    Significant Deficiency Repeat
  • 51155 2022-002
    Significant Deficiency Repeat
  • 51156 2022-002
    Significant Deficiency Repeat
  • 51157 2022-002
    Significant Deficiency Repeat
  • 51158 2022-002
    Significant Deficiency Repeat
  • 51159 2022-002
    Significant Deficiency Repeat
  • 51160 2022-002
    Significant Deficiency Repeat
  • 51161 2022-002
    Significant Deficiency Repeat
  • 51162 2022-002
    Significant Deficiency Repeat
  • 51163 2022-002
    Significant Deficiency Repeat
  • 51164 2022-002
    Significant Deficiency Repeat
  • 51165 2022-002
    Significant Deficiency Repeat
  • 51166 2022-002
    Significant Deficiency Repeat
  • 51167 2022-002
    Significant Deficiency Repeat
  • 51168 2022-002
    Significant Deficiency Repeat
  • 51169 2022-002
    Significant Deficiency Repeat
  • 51170 2022-002
    Significant Deficiency Repeat
  • 51171 2022-002
    Significant Deficiency Repeat
  • 51172 2022-002
    Significant Deficiency Repeat
  • 51173 2022-002
    Significant Deficiency Repeat
  • 51174 2022-002
    Significant Deficiency Repeat
  • 51175 2022-002
    Significant Deficiency Repeat
  • 51176 2022-002
    Significant Deficiency Repeat
  • 627567 2022-002
    Significant Deficiency Repeat
  • 627568 2022-002
    Significant Deficiency Repeat
  • 627569 2022-002
    Significant Deficiency Repeat
  • 627570 2022-002
    Significant Deficiency Repeat
  • 627571 2022-002
    Significant Deficiency Repeat
  • 627572 2022-002
    Significant Deficiency Repeat
  • 627573 2022-002
    Significant Deficiency Repeat
  • 627574 2022-002
    Significant Deficiency Repeat
  • 627575 2022-002
    Significant Deficiency Repeat
  • 627576 2022-002
    Significant Deficiency Repeat
  • 627577 2022-002
    Significant Deficiency Repeat
  • 627579 2022-002
    Significant Deficiency Repeat
  • 627580 2022-002
    Significant Deficiency Repeat
  • 627581 2022-002
    Significant Deficiency Repeat
  • 627582 2022-002
    Significant Deficiency Repeat
  • 627583 2022-002
    Significant Deficiency Repeat
  • 627584 2022-002
    Significant Deficiency Repeat
  • 627585 2022-002
    Significant Deficiency Repeat
  • 627586 2022-002
    Significant Deficiency Repeat
  • 627587 2022-002
    Significant Deficiency Repeat
  • 627588 2022-002
    Significant Deficiency Repeat
  • 627589 2022-002
    Significant Deficiency Repeat
  • 627590 2022-002
    Significant Deficiency Repeat
  • 627591 2022-002
    Significant Deficiency Repeat
  • 627592 2022-002
    Significant Deficiency Repeat
  • 627593 2022-002
    Significant Deficiency Repeat
  • 627594 2022-002
    Significant Deficiency Repeat
  • 627595 2022-002
    Significant Deficiency Repeat
  • 627596 2022-002
    Significant Deficiency Repeat
  • 627597 2022-002
    Significant Deficiency Repeat
  • 627598 2022-002
    Significant Deficiency Repeat
  • 627599 2022-002
    Significant Deficiency Repeat
  • 627600 2022-002
    Significant Deficiency Repeat
  • 627601 2022-002
    Significant Deficiency Repeat
  • 627602 2022-002
    Significant Deficiency Repeat
  • 627603 2022-002
    Significant Deficiency Repeat
  • 627604 2022-002
    Significant Deficiency Repeat
  • 627605 2022-002
    Significant Deficiency Repeat
  • 627606 2022-002
    Significant Deficiency Repeat
  • 627607 2022-002
    Significant Deficiency Repeat
  • 627608 2022-002
    Significant Deficiency Repeat
  • 627609 2022-002
    Significant Deficiency Repeat
  • 627610 2022-002
    Significant Deficiency Repeat
  • 627611 2022-002
    Significant Deficiency Repeat
  • 627612 2022-002
    Significant Deficiency Repeat
  • 627613 2022-002
    Significant Deficiency Repeat
  • 627614 2022-002
    Significant Deficiency Repeat
  • 627615 2022-002
    Significant Deficiency Repeat
  • 627616 2022-002
    Significant Deficiency Repeat
  • 627617 2022-002
    Significant Deficiency Repeat
  • 627618 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.047 Trio_upward Bound $1.06M
93.866 Aging Research $235,197
47.074 Biological Sciences $204,500
47.070 Computer and Information Science and Engineering $190,831
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $168,844
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $155,673
93.310 Trans-Nih Research Support $151,221
93.264 Nurse Faculty Loan Program (nflp) $146,015
93.242 Mental Health Research Grants $142,912
47.041 Engineering $106,363
84.425 Education Stabilization Fund $96,148
12.431 Basic Scientific Research $93,207
93.837 Cardiovascular Diseases Research $88,779
93.658 Foster Care_title IV-E $88,467
81.117 Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/assistance $79,121
97.067 Homeland Security Grant Program $73,527
93.855 Allergy, Immunology and Transplantation Research $73,120
47.076 Education and Human Resources $65,701
15.657 Endangered Species Conservation ? Recovery Implementation Funds $50,047
81.000 Technical Assistance $49,837
93.865 Child Health and Human Development Extramural Research $44,918
12.902 Information Security Grants $40,677
43.009 Cross Agency Support $40,365
93.732 Mental and Behavioral Health Education and Training Grants $39,240
10.310 Agriculture and Food Research Initiative (afri) $36,271
12.903 Gencyber Grants Program $29,083
19.009 Academic Exchange Programs - Undergraduate Programs $28,726
12.420 Military Medical Research and Development $21,095
10.170 Specialty Crop Block Grant Program - Farm Bill $18,135
81.049 Office of Science Financial Assistance Program $16,744
84.305 Education Research, Development and Dissemination $11,560
43.008 Education $10,794
94.013 Volunteers in Service to America $10,712
93.859 Biomedical Research and Research Training $9,805
10.683 National Fish and Wildlife Foundation $7,074
93.136 Injury Prevention and Control Research and State and Community Based Programs $6,845
20.600 State and Community Highway Safety $5,267
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $1,185
93.121 Oral Diseases and Disorders Research $70
47.049 Mathematical and Physical Sciences $-233
20.200 Highway Research and Development Program $-1,063