Finding Text
2023-006 – Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.667 Assistance Listing Name: Social Services Block Grant Pass-through Awards under the Uniform Guidance Requirements: Criteria – CFR 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition – During our testing of reporting, we test selected two reports for testing and noted two exceptions in the ability of management to support payroll reported to for the Title XX federal program, in that the Organization billed for personnel time on a monthly basis (1/12 of the total award) up to the maximum available for personnel costs, versus billing for the actual costs incurred under the award. The United Way of Greater Cleveland did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. Cause – United Way does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Effect – An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs – None. Context – United Way of Greater Cleveland collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure does not exist to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing. Rather, invoicing is done on a pro-rata basis for the entire amount of the personnel cost under the contract, and then an annual comparison to contract was done across programs to provide greater assurance that no costs had been billed and reported in excess of the amounts incurred. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that United Way of Greater Cleveland develop a policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation to support costs reported to the program.