Finding 994667 (2022-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-06-11
Audit: 312179
Organization: Heritage University (WA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: Lack of proper records supporting employee time allocation to federal awards, violating 2 CFR section 200.430.
  • Impacted Requirements: Compensation costs must be based on accurate time and effort reporting; estimates made before services are performed are not acceptable.
  • Recommended Follow-Up: Implement a robust internal control policy for time and effort reporting, ensuring documentation is maintained and verified by both employees and supervisors.

Finding Text

Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

Categories

Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 418206 2022-009
    Significant Deficiency
  • 418207 2022-010
    Significant Deficiency
  • 418208 2022-009
    Significant Deficiency
  • 418209 2022-010
    Significant Deficiency
  • 418210 2022-009
    Significant Deficiency
  • 418211 2022-002
    Material Weakness Repeat
  • 418212 2022-006
    Significant Deficiency
  • 418213 2022-007
    Material Weakness
  • 418214 2022-002
    Material Weakness Repeat
  • 418215 2022-002
    Material Weakness Repeat
  • 418216 2022-003
    Significant Deficiency Repeat
  • 418217 2022-006
    Significant Deficiency
  • 418218 2022-006
    Significant Deficiency
  • 418219 2022-007
    Material Weakness
  • 418220 2022-007
    Material Weakness
  • 418221 2022-008
    Significant Deficiency
  • 418222 2022-004
    Significant Deficiency Repeat
  • 418223 2022-005
    Material Weakness Repeat
  • 418224 2022-005
    Material Weakness Repeat
  • 418225 2022-002
    Material Weakness Repeat
  • 418226 2022-002
    Material Weakness Repeat
  • 418227 2022-002
    Material Weakness Repeat
  • 418228 2022-002
    Material Weakness Repeat
  • 418229 2022-003
    Significant Deficiency Repeat
  • 418230 2022-002
    Material Weakness Repeat
  • 418231 2022-002
    Material Weakness Repeat
  • 994648 2022-009
    Significant Deficiency
  • 994649 2022-010
    Significant Deficiency
  • 994650 2022-009
    Significant Deficiency
  • 994651 2022-010
    Significant Deficiency
  • 994652 2022-009
    Significant Deficiency
  • 994653 2022-002
    Material Weakness Repeat
  • 994654 2022-006
    Significant Deficiency
  • 994655 2022-007
    Material Weakness
  • 994656 2022-002
    Material Weakness Repeat
  • 994657 2022-002
    Material Weakness Repeat
  • 994658 2022-003
    Significant Deficiency Repeat
  • 994659 2022-006
    Significant Deficiency
  • 994660 2022-006
    Significant Deficiency
  • 994661 2022-007
    Material Weakness
  • 994662 2022-007
    Material Weakness
  • 994663 2022-008
    Significant Deficiency
  • 994664 2022-004
    Significant Deficiency Repeat
  • 994665 2022-005
    Material Weakness Repeat
  • 994666 2022-005
    Material Weakness Repeat
  • 994668 2022-002
    Material Weakness Repeat
  • 994669 2022-002
    Material Weakness Repeat
  • 994670 2022-002
    Material Weakness Repeat
  • 994671 2022-003
    Significant Deficiency Repeat
  • 994672 2022-002
    Material Weakness Repeat
  • 994673 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.67M
84.268 Federal Direct Student Loans $2.60M
84.141 Migrant Education_high School Equivalency Program $497,387
84.149 Migrant Education_college Assistance Migrant Program $471,081
84.042 Trio_student Support Services $282,228
84.031 Higher Education_institutional Aid $236,724
84.217 Trio_mcnair Post-Baccalaureate Achievement $234,353
93.011 National Organizations of State and Local Officials $180,020
84.007 Federal Supplemental Educational Opportunity Grants $170,371
93.732 Mental and Behavioral Health Education and Training Grants $104,094
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $84,870
47.074 Biological Sciences $66,342
84.033 Federal Work-Study Program $54,613
10.558 Child and Adult Care Food Program $26,973
43.008 Education $20,649
47.075 Social, Behavioral, and Economic Sciences $12,634
45.164 Promotion of the Humanities_public Programs $9,439
45.310 Grants to States $6,946
45.129 Promotion of the Humanities_federal/state Partnership $6,447
10.310 Agriculture and Food Research Initiative (afri) $6,425
47.076 Education and Human Resources $4,118
84.425 Education Stabilization Fund $2,804
84.038 Federal Perkins Loan Program $2,285