Finding Text
Questioned Cost: None
Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles) prescribe requirements
for allowable costs relative to compensation and substantiation requirements specifically, 2 CFR Part
200.430(i) states “Cost must be supported by a system of internal control which provides reasonable
assurance that the charges are accurate, allowable, and properly allocated.”
Condition: Employee change of status forms are not consistently maintained in accordance with
applicable requirements.
Context: 13 Employee files were selected for verification disclosed 10 instances where forms were
not available for review.
Cause: Employee change of status forms or offer letters were not maintained on file or available for
review.
Effect: Inability to review employee change of status forms or offer letters limits the ability to verify
costs allowability as required. As a result of the missing forms, it is not possible to fully ascertain
compliance with allowable costs as required by 2 CFR 200.430.
Recommendation: Offer letters or employee change of status forms should be maintained on file.
Views of Responsible Official: Personnel files were not maintained while CRA was without a Director
and human resources professional for 2020 and 2021. We have since hired a Human Resources
Director, Beth Anne Falco, who is in the process of bringing all employee files current. As part of the
updated files, CRA intends to issue new employee forms in the beginning of FY25, which will include
updated job descriptions, salary information, payroll, and benefits.