Finding Text
Criteria: 2 CFR 200.430(i) requires the auditee to establish and maintain effective internal control over the allocation of personnel expenses whereby charges to Federal awards for personnel-related expenditures are supported by official records of 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. Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: 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: Personnel expenses were not reconciled to T&E reports during the fiscal year, which resulted in personnel expenses being under-claimed. Cause: Internal controls surrounding time and effort reporting were designed to perform allocation reconciliations based on the award period instead of the fiscal year. Questioned costs: none. Recommendation: We recommend that management implement a process whereby reporting is reconciled based on fiscal year. We recommend that all personnel expenditures allocated to grants are tracked, reviewed, and approved prior to recording in the general ledger. Views of responsible officials and planned corrective actions: See attached corrective action plan.