Finding 9289 (2023-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-01-22
Audit: 12740
Organization: Family First Health Corporation (PA)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center failed to complete time and effort attestations for employees in fiscal year 2023, leading to potential inaccuracies in payroll costs charged to federal grants.
  • Impacted Requirements: Compliance with federal regulations on allowable costs and internal controls over salary charges was not met, as charges were based on budget estimates rather than actual work performed.
  • Recommended Follow-Up: Implement timely signing of time and effort attestations by employees and supervisors, and review the Time and Effort policy to ensure compliance with federal guidelines.

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.

Categories

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 9285 2023-003
    Material Weakness Repeat
  • 9286 2023-003
    Material Weakness Repeat
  • 9287 2023-003
    Material Weakness Repeat
  • 9288 2023-003
    Material Weakness Repeat
  • 9290 2023-004
    Significant Deficiency Repeat
  • 585727 2023-003
    Material Weakness Repeat
  • 585728 2023-003
    Material Weakness Repeat
  • 585729 2023-003
    Material Weakness Repeat
  • 585730 2023-003
    Material Weakness Repeat
  • 585731 2023-003
    Material Weakness Repeat
  • 585732 2023-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.01M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.60M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.27M
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $880,011
93.558 Temporary Assistance for Needy Families $788,926
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $774,535
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $539,957
32.006 Covid-19 Telehealth Program $205,991
93.788 Opioid Str $152,703
93.268 Covid-19 Immunization Cooperative Agreements $87,877
93.527 Covid-19 Fy 2023 Expanding Covid-19 Vaccination $85,355
93.556 Promoting Safe and Stable Families $84,272
93.217 Family Planning_services $72,500
93.667 Social Services Block Grant $36,308
93.994 Maternal and Child Health Services Block Grant to the States $14,376