Finding Text
2023-001 Activities Allowed or Unallowed and Allowable Costs/Costs Principles
Program: COVID-19 Emergency Rental Assistance Program
Federal Assistance Listing No: 21.023
County Recipient: Community Action Partnership of Natrona County (CAP)
Federal Agency: U.S. Department of the Treasury
Grant year: 2023
Federal Award Identification: Unknown
Applicable Pass-through Entity: Wyoming Department of Family Services
Criteria
Accounting practices of the non-Federal entity must provide for adequate documentation to support costs charged to the Federal award. Additionally, standards for documentation of personnel expenses in Uniform Guidance 2 CFR part 200.430 Compensation – personal services state that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among various other requirements, these records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
• Support the distribution of the employee’s salary or wages among specific activities or costs objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
• In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA) (29 CFR part 516), charges for the salaries and wages of nonexempt employees, in addition to the supporting documentation described in this section, must also be supported by records indicating the total number of hours worked each day.
Condition
CAP was missing a consistent system of internal control for tracking and approving the salaries and wages and other costs charged to the federal program. There were several timecards and transactions that were not approved by the supervisor or another individual knowledgeable of the grant. Additionally, journal entries were posted to classify salaries and wages to the grant without a supporting allocation and approval.
For the transactions that were lacking support it was not possible to verify the costs were allowable. Therefore the amounts associated with these transactions are reported as questioned costs.
Cause
Due to turnover in grant management, processes that had previously existed were overlooked, which resulted in a lack of consistent approval of costs and an inconsistent system for the allocation of salaries and wages charged to the grant. Additionally, records that reflect the work performed were unavailable.
Effect or potential effect
CAP was unable to provide supporting documentation that the costs allocated to the grant were allowable.
Questioned Cost
$17,393
Context
The internal control and compliance testing performed included testing 60 transactions out of 270 total grant transactions. Of the items tested, 32% of the transactions were missing approvals or adequate supporting documentation of the time and expense allocated to the grant.
Identification as a repeat finding
This is not a repeat finding.
Recommendation
We recommend CAP review its policies and procedures related to the internal controls over payroll and other transactions related to grants.
Views of Responsible Officials
CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight.
Payroll services were outsourced to ADP payroll services in order to provide real time features and accountability for time. This allows recording of time more accurate, reliable and allocable. Payroll records are reviewed and time studies are being performed for all staff to ensure allocation methodology, once selected is appropriate, consistent and in alignment with staff performance.
Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes:
All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations.
See Corrective Action Plan