Finding Text
Crime Victim Assistance
U.S. Department of Justice
Passed through California Office of Emergency Services
Federal Catalog Number 16.575
Federal Award Identification Number XC 22 05 1248
(January 1, 2023 - December 31, 2023)
Federal Award Identification Number RC 22 31 1248
(October 1, 2022 - September 30, 2023)
Federal Award Identification Number XL 21 04 1248
(January 1, 2022 - December 31, 2022)
Federal Award Identification Number SP 22 05 1248
(May 1, 2023 - April 30, 2024)
Federal Award Identification Number XH 21 04 1248
(January 1, 2022 - December 31, 2022)
Criteria
Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), The Internal Control - Integrated Framework, published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and numerous federal guidelines require the establishment and maintenance of internal control designed to reasonable ensure accurate financial reporting and compliance with laws, regulations and program requirements. The Organization is required to be in compliance with the criteria contained in 2 CFR Part 200. 430(i)(1 )(viii). Which require documentation of personnel expenses based on:
"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. Short term (such as one or two months) fluctuation between workload categories need not to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
C. The non-Federal entity's system of internal controls includes processes to review after-the- fact interim charges made to a Federal award 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
The budgeted allocation of salaried employees' wages among multiple projects were not reviewed and adjusted after-the-fact as required by 2 CFR Section 200.403(i)(1 )(viii). Questioned Costs
The known questioned costs were $1,427 of personnel costs charges to federal program.
Proper Perspective
Twenty-eight payroll cash disbursements were tested totaling $25,645. The total sample population was $1,221,287. Therefore, likely questioned costs are $36,471. Our sample was a statistically valid sample. The issue is systematic to the organization's salaried employee payroll process.
Effect
The Organization is out of compliance with Uniform Guidance requirements for Allowable Costs/Cost Principle.
Cause
The Organization's internal control process over charging salaried personnel cost based on the labor distribution report, does not include an after-the-fact review and adjustment based on actual time worked.
Recommendation
We recommend that the Organization have support for the distribution of the employees' wages among each project. If budget or estimates are used for allocations among projects, we recommend an after- the-fact review is done and the necessary adjustments are made to the final amount charged for that period to ensure the amount charges to the project is accurate, allowable and properly allocated following the requirements of 2 CFR Section 200.430(i)(1 )(viii).