Finding 946439 (2023-002)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-02-21

AI Summary

  • Core Issue: BBBSC relied on budget estimates for salary reimbursements instead of actual work records, violating federal guidelines.
  • Impacted Requirements: Compliance with Title 2 U.S. Code of Federal Regulations Part 200, specifically section 200.430, regarding accurate documentation of salary charges.
  • Recommended Follow-up: Ensure ongoing documentation of actual time worked and implement regular reviews to verify compliance with federal requirements.

Finding Text

Federal Agency: U.S. Department of Justice Federal Program and Assistance Listing Number: Juvenile Mentoring Program, 16.726 Identification Number: 15PJDP-22-AG-04915-MENT Grant Period: October 1, 2022 – December 31, 2023 2023-002 Allowable Costs/Cost Principles – Material Weakness in Internal Control over Compliance Criteria and Condition: According to Title 2 U.S Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), section 200.430, 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 alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that the system for establishing the estimates produces reasonable approximations of the activity actually performed; significant changes in the corresponding work activity are identified and entered into the records in a timely manner; and the non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges based on budget estimates. All personnel salary or wages through July 2023 were based on budget estimates as documented in the approved grant budget for personnel costs and fringe benefit costs related to the OJ5 grant. However, there was no evidence of an after-the-fact review to determine that the distribution accurately reflected the work performed by the employee. Cause: For all employees who charged time to the grant, BBBSC requires that timesheets be completed with each pay-period that support the disbursement of the wages. However, from October 2022 through July 2023, BBBSC was using the budgeted personnel costs and fringe benefit costs to request reimbursements related to the OJ5 grant. Instead of basing the requests on actual time incurred related to the grant, BBBSC was using the percentage of time from the budget and multiplying it by the total compensation for each pay period for each employee allocated to the grant. Effect: When adequate support is not obtained and used to support the amount charged to the federal program or supported by an after-the-fact review, there is a risk that unsupported or inaccurate costs are being charged to the federal program. Context: When evaluating internal controls for OJ5 grant personnel expenses, it was determined that management used budgeted amounts for the majority of the year’s reimbursement requests, instead of actual costs. Questioned Costs: Known questioned costs total $286,676. Identification of Repeat Findings: This is not a repeat finding. Recommendation: Proper control activities should be implemented to allow for a consistent, accurate, and allowable method to support distribution of personnel charges to federal programs. If management elects to continue to allocate personnel charged based on a budget estimate, the after-the-fact review should be properly documented. Views of Responsible Officials and Planned Corrective Actions: As of August 2023, BBBSC implemented controls that properly support the distribution of personnel charges in accordance with the Uniform Guidance and employees’ salaries charged to the grant are based on actual costs incurred. Further, these charges are reviewed by the Director of Finance before federal reimbursements are requested.

Categories

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

Other Findings in this Audit

  • 369997 2023-002
    Material Weakness
  • 369998 2023-003
    Significant Deficiency
  • 369999 2023-003
    Significant Deficiency
  • 370000 2023-004
    Significant Deficiency
  • 946440 2023-003
    Significant Deficiency
  • 946441 2023-003
    Significant Deficiency
  • 946442 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.726 Juvenile Mentoring Program $264,606