Finding 9923 (2023-001)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-01-25
Audit: 13558
Organization: First Step, Inc. (AR)
Auditor: Ata PLLC

AI Summary

  • Core Issue: Grant compliance was violated due to early retention bonus payments made to employees before the required six-month employment period.
  • Impacted Requirements: The ARPA grant specifies that retention bonuses can only be paid to employees who have completed six continuous months of employment.
  • Recommended Follow-Up: Management should fix the tracking spreadsheet formulas and implement a review process by HR or payroll before approving bonus payments.

Finding Text

Failure to comply with grant time-based requirements U.S. Department of Treasury - ALN: 21.019 COVID Funds Known and likely questioned costs: Known: $1,398, Likely: 18,509 Condition: During audit testing it was found in 10% of the sampled population were paid incorrectly, resulting in overpayment to employees and departure from grant compliance. Employees were given retention bonuses before the mandated 6 month mark as outlined in the compliance requirements of the ARPA grant. Criteria: ARPA grant document states "The retention bonus incentive category allows for bonus payments to DSPs who exceeded six (6) continuous months of employment with the same employer." Requirement #3: "The provider must certify the DSP completed six (6) continuous months of employment". Cause: Improper internal controls allowed the spreadsheet, created internally for tracking hire dates and their 6 month marks, was incorrectly calculating the fiscal year number of days and was not under review by a second employee. Effect: Known misuse of funding was $1,397.50, and when applied to the entire population resulted in likely early payment of $18,509. Departure from grant compliance. Recommendation: We recommend that management corrects the formulas on their tracking spreadsheet and require that a member of HR or payroll review the employees hire dates and bonus dates before the payment is approved. Management Response: All funds have been expended and spreadsheet was reviewed after it was brought to my attention during fieldwork.

Corrective Action Plan

Failure to comply with grant time-based requirements. Recommendation: We recommend that First Step corrects the formula in their bonus and hire date tracking spreadsheet to include 365 days of the year instead of a 360-day cycle. Additionally, we recommend payroll or HR reviews the bonus time frames provided by management before dispersing the payment. Action Taken: Chris Smith, CFO, has since updated spreadsheet used in calculation of bonuses. Going forward, any funding of this nature will have an initial review by HR before going to management and payment is disbursed. Name of person responsible for corrective action: Chris Smith, CFO Anticipated completion date for the corrective action: December 31, 2023

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 586365 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.019 Coronavirus Relief Fund $806,742
10.558 Child and Adult Care Food Program $574,272
84.187 Supported Employment Services for Individuals with the Most Significant Disabilities $39,000
10.555 National School Lunch Program $20,875
10.565 Commodity Supplemental Food Program $14,768