Finding 971878 (2023-003)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-04-30
Audit: 305163
Organization: The Literacy Lab (DC)
Auditor: Sb & Company LLC

AI Summary

  • Core Issue: Inadequate documentation for payroll transactions led to 24 exceptions in testing, raising concerns about the accuracy of salary charges to the grant.
  • Impacted Requirements: Compliance with Uniform Guidance is compromised due to insufficient internal controls over time and effort documentation.
  • Recommended Follow-Up: Implement policies to ensure tracking and documentation of salary adjustments based on actual employee time distribution, reviewed at least annually.

Finding Text

U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls 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, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost 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. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 395408 2023-001
    Significant Deficiency
  • 395409 2023-002
    Significant Deficiency
  • 395410 2023-001
    Significant Deficiency
  • 395411 2023-002
    Significant Deficiency
  • 395412 2023-001
    Significant Deficiency
  • 395413 2023-002
    Significant Deficiency
  • 395414 2023-001
    Significant Deficiency
  • 395415 2023-002
    Significant Deficiency
  • 395416 2023-001
    Significant Deficiency
  • 395417 2023-002
    Significant Deficiency
  • 395418 2023-001
    Significant Deficiency
  • 395419 2023-002
    Significant Deficiency
  • 395420 2023-001
    Significant Deficiency
  • 395421 2023-002
    Significant Deficiency
  • 395422 2023-001
    Significant Deficiency
  • 395423 2023-002
    Significant Deficiency
  • 395424 2023-001
    Significant Deficiency
  • 395425 2023-002
    Significant Deficiency
  • 395426 2023-001
    Significant Deficiency
  • 395427 2023-002
    Significant Deficiency
  • 395428 2023-001
    Significant Deficiency
  • 395429 2023-002
    Significant Deficiency
  • 395430 2023-001
    Significant Deficiency
  • 395431 2023-002
    Significant Deficiency
  • 395432 2023-001
    Significant Deficiency
  • 395433 2023-002
    Significant Deficiency
  • 395434 2023-003
    Significant Deficiency
  • 395435 2023-003
    Significant Deficiency
  • 395436 2023-003
    Significant Deficiency
  • 395437 2023-003
    Significant Deficiency
  • 971850 2023-001
    Significant Deficiency
  • 971851 2023-002
    Significant Deficiency
  • 971852 2023-001
    Significant Deficiency
  • 971853 2023-002
    Significant Deficiency
  • 971854 2023-001
    Significant Deficiency
  • 971855 2023-002
    Significant Deficiency
  • 971856 2023-001
    Significant Deficiency
  • 971857 2023-002
    Significant Deficiency
  • 971858 2023-001
    Significant Deficiency
  • 971859 2023-002
    Significant Deficiency
  • 971860 2023-001
    Significant Deficiency
  • 971861 2023-002
    Significant Deficiency
  • 971862 2023-001
    Significant Deficiency
  • 971863 2023-002
    Significant Deficiency
  • 971864 2023-001
    Significant Deficiency
  • 971865 2023-002
    Significant Deficiency
  • 971866 2023-001
    Significant Deficiency
  • 971867 2023-002
    Significant Deficiency
  • 971868 2023-001
    Significant Deficiency
  • 971869 2023-002
    Significant Deficiency
  • 971870 2023-001
    Significant Deficiency
  • 971871 2023-002
    Significant Deficiency
  • 971872 2023-001
    Significant Deficiency
  • 971873 2023-002
    Significant Deficiency
  • 971874 2023-001
    Significant Deficiency
  • 971875 2023-002
    Significant Deficiency
  • 971876 2023-003
    Significant Deficiency
  • 971877 2023-003
    Significant Deficiency
  • 971879 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
94.006 Americorps National Direct $1.09M
84.425 Education Stabilization Fund - American Rescue Plan - Elementary and Secondary School Emergency Relief $866,378
94.006 Va Reading Corps $689,079
94.006 Ma Reading Corps $517,754
94.006 Mo Reading Corps $470,992
94.006 Ma Reading Corps - Arp Match Replacement $397,514
94.006 Va Reading Corps - Arp Match Replacement $360,729
94.006 Dc Reading Corps $349,906
94.006 Mo Reading Corps - Arp Match Replacement $343,156
94.006 MD Reading Corps $301,643
21.027 Coronavirus State and Local Fiscal Recovery Funds $291,432
94.006 Dc Reading Corps - Arp Match Replacement $238,268
94.006 MD Reading Corps - Arp Match Replacement $218,605
94.006 CO Reading Corps - Planning Grant $3,899