EIN: 112934620
UEI: FKH4JKWKKSG1
Audited by: Mengel Metzger Barr & Co.,LLP
Oversight agency: 17 [Department of Labor]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 29, 2026 (31 days from today).
What is a management decision? →FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
Criteria: The Organization should adhere to all approved financial policies and procedures. Condition and Context: Currently, the Organization has stated policies related to credit cards and personnel files that are not properly being followed. The credit card policy states that receipts must be obtained and approval for purchases over $500 must be obtained from the CEO. During our testing of two months, November 2023 and April 2024, we noted two charges totaling $1,813 that did not have proper supporting documentation. Cause: The Organization has a small number of accounting personnel who, along with being tasked with many responsibilities that are typically spread among a larger accounting department, were unfamiliar with the policies. Effect or Potential Effect: The current condition could allow for the potential for personal expenses to be charged to the Organization’s credit cards or individuals may receive inaccurate amounts for wages with no support being maintained. For transactions related to federal grants without the appropriate supporting documentation, costs may be disallowed. Recommendation: Management should gain a thorough understanding of the approved financial policies and procedures to ensure all are being adhered to. If the policies are no longer reflective of actual operations, management should revise the policies and procedures. Repeat finding: Yes, 2023-002. Views of Responsible Officials: Management of the Organization concurs with the audit finding and will review the financial policies and procedures, reinforcing those that are applicable and making necessary changes as needed.
Show full finding ▾Hide full finding ▴Criteria: The Organization should adhere to all approved financial policies and procedures. Condition and Context: Currently, the Organization has stated policies related to credit cards and personnel files that are not properly being followed. The credit card policy states that receipts must be obtained and approval for purchases over $500 must be obtained from the CEO. During our testing of two months, November 2023 and April 2024, we noted two charges totaling $1,813 that did not have proper supporting documentation. Cause: The Organization has a small number of accounting personnel who, along with being tasked with many responsibilities that are typically spread among a larger accounting department, were unfamiliar with the policies. Effect or Potential Effect: The current condition could allow for the potential for personal expenses to be charged to the Organization’s credit cards or individuals may receive inaccurate amounts for wages with no support being maintained. For transactions related to federal grants without the appropriate supporting documentation, costs may be disallowed. Recommendation: Management should gain a thorough understanding of the approved financial policies and procedures to ensure all are being adhered to. If the policies are no longer reflective of actual operations, management should revise the policies and procedures. Repeat finding: Yes, 2023-002. Views of Responsible Officials: Management of the Organization concurs with the audit finding and will review the financial policies and procedures, reinforcing those that are applicable and making necessary changes as needed.
Plan: 1. Mandatory Time and Program Effort Records: OBT will continue to allocate as many staff as possible to a single contract that reflects where they spend 100% of their time. Further, as of July 2025, OBT will only have one such federal contract and this contract has a required staffing pattern of six full-time staff who must spend 100% of their time on this program. 2. Internal Controls: Payroll reports are reviewed every payroll for accuracy. OBT has implemented internal controls to review and verify the accuracy of time and effort records, ensuring that charges to federal awards comply with regulations. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement this plan by March 31, 2025, with ongoing monitoring and improvement.
2023-003
During our testing for the year ended June 30, 2024, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $41,865 Context: As most employees work specifically on a single program, there was one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $41,865. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. Repeat finding: Yes, 2023-003. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2025.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535B / 90536B / 90537B / 90538B. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2024, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $41,865 Context: As most employees work specifically on a single program, there was one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $41,865. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. Repeat finding: Yes, 2023-003. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2025.
Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awareness: OBT has provided training to all relevant personnel, especially those involved in procurement, expenditure documentation collection, and allocation designation to ensure they understand the requirements of federal awards and the importance of proper documentation. 3. New Technology: OBT Has purchased new technology to better support documentation collection and allocations for all orders made. 4. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement all four steps within this plan by March 31, 2025, with ongoing monitoring and improvement.
2023-004
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
During our testing for the year ended June 30, 2023, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $65,379 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $65,379. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. Repeat finding: Yes, 2022-003. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2023, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $65,379 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $65,379. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. Repeat finding: Yes, 2022-003. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Finding 2023-003: Inadequate Documentation of Employee Time and Effort Allocation for Federal Program Identification of the Federal Program: Assistance Listing Number 17.259 - WIOA Youth Activities Program - U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles. Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2023, we noted a lack of detail for employee's actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources was entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $65,379 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $65,379. Plan: 1. Mandatory Time and Program Effort Records: OBT has implemented allocations by program in our payroll software. Hourly employees allocated to multiple programs will clock in and out for each program and all timecards are approved by management. Reports are reviewed every payroll for accuracy. 2. Training: OBT has provided training to all employees on the importance of accurate time and effort reporting for federal programs, ensuring that employees understand the requirements and their responsibilities in maintaining these records. 3. Internal Controls: OBT has implemented internal controls to review and verify the accuracy of time and effort records, ensuring that charges to federal awards comply with regulations. 4. Monitoring and Auditing: OBT conducts regular monitoring and internal audits to validate the accuracy and completeness of time and effort records. Name of Contact Person: Carla Licavoli, Chief Operating & Compliance Officer Target Date: OBT implemented all four steps within this plan by December 31, 2023, with ongoing monitoring and improvement.
2022-003
During our testing of 42 disbursements for the year ended June 30, 2023, we noted that there were 22 instances where there was a lack of adequate documentation or the amount allocated to the major program could not be substantiated. Cause: With personnel changes at most levels within the Organization, documentation from the former employees could not be located and the current employees were unfamiliar with the requirements of the federal awards. Effect or Potential Effect: Due to the lack of internal controls in this area, support for various expenditures were not able to be located which could lead to costs being allocated improperly to the federal grants. Questioned Costs: $338,554. Context: In our testing sample, approximately 32% of total expenditures tested did not have proper documentation or the allocation to the federal award could not be provided. The potential error was extrapolated to the population leading to questioned costs of $338,554. Recommendation: We recommend the Organization implement proper internal controls over compliance with allowable cost principles, including maintaining support for allocation methodologies used and costs incurred, and to ensure costs relate to the federal program to which they are charged. Repeat finding: Yes, 2022-004. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The Organization has implemented procedures to improve document retention and support for allocations to the federal grant during the year ending June 30, 2024.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200 Subpart E of the Uniform Guidance states that costs charged to federal awards must be determined in accordance with GAAP, be adequately documented, and be allocable to the federal award, and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of 42 disbursements for the year ended June 30, 2023, we noted that there were 22 instances where there was a lack of adequate documentation or the amount allocated to the major program could not be substantiated. Cause: With personnel changes at most levels within the Organization, documentation from the former employees could not be located and the current employees were unfamiliar with the requirements of the federal awards. Effect or Potential Effect: Due to the lack of internal controls in this area, support for various expenditures were not able to be located which could lead to costs being allocated improperly to the federal grants. Questioned Costs: $338,554. Context: In our testing sample, approximately 32% of total expenditures tested did not have proper documentation or the allocation to the federal award could not be provided. The potential error was extrapolated to the population leading to questioned costs of $338,554. Recommendation: We recommend the Organization implement proper internal controls over compliance with allowable cost principles, including maintaining support for allocation methodologies used and costs incurred, and to ensure costs relate to the federal program to which they are charged. Repeat finding: Yes, 2022-004. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The Organization has implemented procedures to improve document retention and support for allocations to the federal grant during the year ending June 30, 2024.
Finding 2023-004: Lack of Documentation and Internal Controls for Federal Program Expenditures Identification of the Federal Program: Assistance Listing Number 17.259 - WIOA Youth Activities Program - U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles. Criteria: Requirements per section 2 CFR Part 200 Subpart E of the Uniform Guidance state that costs charged to federal awards must be determined in accordance with GAAP (Generally Accepted Accounting Principles), be adequately documented, and be allocable to the federal award, and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of 42 disbursements for the year ended June 30, 2023, we noted that there were 22 instances where there was a lack of adequate documentation, or the amount allocated to the major program could not be substantiated. Cause: With personnel changes at most levels within the Organization, documentation from the former employees could not be located, and the current employees were unfamiliar with the requirements of the federal awards. Effect or Potential Effect: Due to the lack of internal controls in this area, support for various expenditures could not be found, which could lead to costs being allocated improperly to the federal grants. Questioned Costs: $338,554 Context: In our testing sample, approximately 32% of total expenditures tested did not have proper documentation or the allocation to the federal award could not be provided. The potential error was extrapolated to the population leading to questioned costs of $338,554. Plan: 1. Internal Control Review: OBT conducted a thorough review of internal controls related to compliance with allowable cost principles, including the documentation of expenditures and allocation methodologies used. OBT has contracted with a new financial firm (BDO) familiar with government awards and allowable expenses. Each expense is now reviewed by two members of the executive team and the accounting contractor, making sure allocations are appropriately recorded in the GL (General Ledgers). 2. Documentation Enhancement: OBT has enhanced document retention procedures to ensure that all required documentation for federal program expenditures is adequately retained, including records of allocation methodologies. 3. Training and Awareness: OBT has provided training to all relevant personnel, especially those involved in expenditure documentation and allocation to ensure they understand the requirements of federal awards and the importance of proper documentation. 4. Documentation Verification: OBT has implemented procedures for ongoing verification and reconciliation of expenditures to ensure they are accurate, allowable, and properly allocated. BDO has also shared best practices. 5. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. . Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT implemented all five steps within this plan by December 31, 2023, with ongoing monitoring and improvement.
2022-004
FAC accepted this audit on October 25, 2023 — management decision was due April 25, 2024.
During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200.430 of the Uniform Guidance state that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing for the year ended June 30, 2022, we noted a lack of detail for employee’s actual hours spent on different programs. Time and effort are allocated based on budgeted amounts. Cause: Allocation to funding sources were entered into the payroll system based on budgeted estimates rather than actual time records. Effect or Potential Effect: The lack of contemporaneous documentation of employee hours worked by grant or federal program could allow the Organization to improperly allocate employee pay to federal grants. Questioned Costs: $46,460 Context: As most employees work specifically on a single program, there was only one employee that worked on multiple programs for which time spent on the program could not be substantiated. The total questioned cost allocated to the program for this person totaled $46,460. Recommendation: The Organization should implement a requirement for employees, both exempt and nonexempt, to maintain accurate records of hours worked by program. View of Responsible Officials: The Organization concurs with the finding and the related recommendations. Management has begun to implement mandatory time and program effort records during the year ending June 30, 2024.
Plan: 1. Mandatory Time and Program Effort Records: OBT has implemented allocations by program in our payroll software. Hourly employees allocated to multiple programs will clock in and out for each program and all timecards are approved by management. Reports are reviewed every payroll for accuracy. 2. Training: OBT will provide training to all employees on the importance of accurate time and effort reporting for federal programs, ensuring that employees understand the requirements and their responsibilities in maintaining these records. 3. Internal Controls: OBT has implemented internal controls to review and verify the accuracy of time and effort records, ensuring that charges to federal awards comply with regulations. 4. Monitoring and Auditing: OBT will conduct regular monitoring and internal audits quarterly to validate the accuracy and completeness of time and effort records. Name of Contact Person: Carla Licavoli, Chief Operating & Compliance Officer Target Date: Management has already begun implementing mandatory time and program effort records during the year ending June 30, 2024. OBT will continue to monitor and improve these processes, ensuring full compliance with federal regulations and reducing the risk of questioned costs.
During our testing of 43 disbursements for the year ended June 30, 2022, we noted that there were 22 instances where there was a lack of adequate documentation or the amount allocated to the major program could not be substantiated. Cause: With personnel changes at most levels within the Organization, documentation from the former employees could not be located and the current employees were unfamiliar with the requirements of the federal awards. Effect or Potential Effect: Due to the lack of internal controls in this area, support for various expenditures were not able to be located which could lead costs being allocated improperly to the federal grants. Questioned Costs: $586,229 Context: In our testing sample, approximately 56% of total expenditures tested did not have proper documentation or the allocation to the federal award could not be provided. The potential error was extrapolated to the population leading to questioned costs of $586,229. Recommendation: We recommend the Organization implement proper internal controls over compliance with allowable cost principles, including maintaining support for allocation methodologies used and costs incurred, and to ensure costs relate to the federal program to which they are charged. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The Organization has implemented procedures to improve document retention and support for allocations to the federal grant during the year ending June 30, 2024.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Allowable Costs/Cost Principles Criteria: Requirements per section 2 CFR Part 200 Subpart E of the Uniform Guidance states that costs charged to federal awards must be determined in accordance with GAAP, be adequately documented, and be allocable to the federal award, and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of 43 disbursements for the year ended June 30, 2022, we noted that there were 22 instances where there was a lack of adequate documentation or the amount allocated to the major program could not be substantiated. Cause: With personnel changes at most levels within the Organization, documentation from the former employees could not be located and the current employees were unfamiliar with the requirements of the federal awards. Effect or Potential Effect: Due to the lack of internal controls in this area, support for various expenditures were not able to be located which could lead costs being allocated improperly to the federal grants. Questioned Costs: $586,229 Context: In our testing sample, approximately 56% of total expenditures tested did not have proper documentation or the allocation to the federal award could not be provided. The potential error was extrapolated to the population leading to questioned costs of $586,229. Recommendation: We recommend the Organization implement proper internal controls over compliance with allowable cost principles, including maintaining support for allocation methodologies used and costs incurred, and to ensure costs relate to the federal program to which they are charged. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The Organization has implemented procedures to improve document retention and support for allocations to the federal grant during the year ending June 30, 2024.
Plan: 1. Internal Control Review: OBT has been conducting a thorough review of internal controls related to compliance with allowable cost principles, including the documentation of expenditures and allocation methodologies used. OBT has contracted with a new financial firm familiar with government awards and allowable expenses. Each expense must be reviewed by two members of the executive team and the accounting contractor, making sure allocations are appropriately recorded in the GL (General Ledgers). 2. Documentation Enhancement: OBT has been enhancing document retention procedures to ensure that all required documentation for federal program expenditures is adequately retained, including records of allocation methodologies. 3. Training and Awareness: OBT will work in collaboration with our new financial consultants to provide training to all relevant personnel, especially those involved in expenditure documentation and allocation to ensure they understand the requirements of federal awards and the importance of proper documentation. Training will begin with the onboarding of the new financial consultant (September 2023) and will occur as often as needed in the first six months and then bi-annually. 4. Documentation Verification: OBT is currently implementing procedures for ongoing verification and reconciliation of expenditures to ensure they are accurate, allowable, and properly allocated. A review by the finance consultants is currently underway and a report will be received by OBT with best practices. 5. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. . Name of Contact Person: Carla Licavoli, Chief Operating & Compliance Officer Target Date: OBT will ensure that the recommended actions are fully implemented and operational by the year ending June 30, 2024, and that these procedures will continue to be monitored and improved to prevent future questioned costs. With the completion of the review by the finance consultants expected by October 2023, OBT will create a process and protocol manual by December 2023 and begin training relevant staff in January 2023.
As a result of the timing of the audit, the applicable reporting deadline was not met. Cause: With personnel changes at most levels within the Organization and delays attributed to the additional findings above, the audit and data collection form were not able to be completed by the stated deadline. Effect or Potential Effect: The reporting deadline was not met which could lead to loss of federal awards. Questioned Costs: Not applicable. Context: Not applicable. Recommendation: We recommend the Organization addresses the additional findings listed above which will lead to the timely completion of the audit and timely submission of the data collection form. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The data collection form will be timely submitted for the year ended June 30, 2023.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: Assistance Listing Number 17.259 – WIOA Youth Activities Program – U.S. Department of Labor. Pass-through Entity: New York City Department of Youth and Community Development. Award Number: 90535A / 90536A / 90537A / 90538A. Compliance Requirement: Reporting Criteria: Requirements per section 2 CFR Part 200.512 of the Uniform Guidance states that the audit and data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: As a result of the timing of the audit, the applicable reporting deadline was not met. Cause: With personnel changes at most levels within the Organization and delays attributed to the additional findings above, the audit and data collection form were not able to be completed by the stated deadline. Effect or Potential Effect: The reporting deadline was not met which could lead to loss of federal awards. Questioned Costs: Not applicable. Context: Not applicable. Recommendation: We recommend the Organization addresses the additional findings listed above which will lead to the timely completion of the audit and timely submission of the data collection form. View of Responsible Officials: The Organization concurs with the finding and the related recommendation. The data collection form will be timely submitted for the year ended June 30, 2023.
Plan: 1. Audit and data collection form will be filed timely starting with the year ended June 30, 2023 filings. . Name of Contact Person: Carla Licavoli, Chief Operating & Compliance Officer Target Date: Filings to be completed by the applicable deadlines starting with the June 30, 2023 submissions.
FAC accepted this audit on August 28, 2022 — management decision was due February 28, 2023.
FAC accepted this audit on September 28, 2021 — management decision was due March 28, 2022.
Currently, time sheets are maintained for all employees, but they do not specify actual time spent for each program or function. Time and effort of employees are allocated based on estimates and budget limitations. Cause: Allocation to funding sources were entered in the payroll system based on budget estimates rather than timekeeping reports. Effect: The amount of personal services charged to the Federal award does not meet the documentation requirements outlined in Cost Principles of Uniform Guidance. Questioned Costs: Out of the entire population of staff charged to the major program only two employees worked on multiple programs for which timesheets could not substantiate time and effort. The total payroll costs related to these employees amounted to $52,296. Context: Timesheets of the Organization do not specify actual time spent on each specific program. In the instances when employees work regular hours on one program and overtime hours on a different program, employees are required to complete separate timesheets for each program. However, employees that work regular hours on multiple programs will complete only one timesheet that does not substantiate time and effort among multiple programs. There were only two employees that were charged to the Federal award of this nature. Repeat Finding: Yes Recommendation: We recommend that all personnel use a timesheet to track their actual time spent working on each program and that be used as the basis for recording salary to the books and used as the source of costs that get charged to Federal awards. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴2020-001 ? Activities Allowed/Allowable Costs Program: CFDA# 17.259 ? WIOA Youth Activities Sponsor Award Number: 90535/90536/90537/90538/C18414GG Sponsor Agency: U.S. Department of Labor passed through New York City Department of Youth and Community Development and New York State Department of Labor Criteria: 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 control 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; (v)Comply with the established accounting policies and practices of the non-Federal entity; (vii)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. Citation: 2 CFR 200.430(i) Condition: Currently, time sheets are maintained for all employees, but they do not specify actual time spent for each program or function. Time and effort of employees are allocated based on estimates and budget limitations. Cause: Allocation to funding sources were entered in the payroll system based on budget estimates rather than timekeeping reports. Effect: The amount of personal services charged to the Federal award does not meet the documentation requirements outlined in Cost Principles of Uniform Guidance. Questioned Costs: Out of the entire population of staff charged to the major program only two employees worked on multiple programs for which timesheets could not substantiate time and effort. The total payroll costs related to these employees amounted to $52,296. Context: Timesheets of the Organization do not specify actual time spent on each specific program. In the instances when employees work regular hours on one program and overtime hours on a different program, employees are required to complete separate timesheets for each program. However, employees that work regular hours on multiple programs will complete only one timesheet that does not substantiate time and effort among multiple programs. There were only two employees that were charged to the Federal award of this nature. Repeat Finding: Yes Recommendation: We recommend that all personnel use a timesheet to track their actual time spent working on each program and that be used as the basis for recording salary to the books and used as the source of costs that get charged to Federal awards. Views of Responsible Officials: See Corrective Action Plan attached.
All employees record their time worked on a daily basis in our ADP payroll system. However, we will implement an additional process in our payroll system to allow employees that work on Federal awards to track their time spent on these awards.
2019-001
We noted transactions that related to the prior fiscal year were erroneously included on claim requests of the current fiscal year and transactions related to the current fiscal year were erroneously included on claim requests of the subsequent fiscal year. Cause: The Organization does not accurately accrue expenses at year end. Effect: Costs charged to the Federal award were not consistently recorded in the proper period. This resulted in situations where reimbursements were requested for costs that did not relate to the funding period and are therefore unallowable. Questioned Costs: The total amount of known or likely questioned costs is less than $25,000. Context: We reviewed payroll expenses for July 2019, which included expenses of $6,375 relating to the prior fiscal year. We also noted expenses relating to June 2020 of $5,977 were not claimed during this fiscal year, but in July 2020. The total error nets to $398. Repeat Finding: Yes Recommendation: We recommend that the Organization implement procedures to ensure that all costs that are incurred during the reporting period are properly accrued and charged to the Federal award in the same period. Payroll costs that relate to the reporting period should also be accrued at year end and coded to the specific funding source code. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴2020-002 ? Activities Allowed/Allowable Costs Program: CFDA# 17.259 ? WIOA Youth Activities Sponsor Award Number: 90535/90536/90537/90538/C18414GG Sponsor Agency: U.S. Department of Labor passed through New York City Department of Youth and Community Development and New York State Department of Labor Criteria: Expenses must be claimed in the period they were incurred. Citation: 2 CFR 230, 2 CFR 215.28 Condition: We noted transactions that related to the prior fiscal year were erroneously included on claim requests of the current fiscal year and transactions related to the current fiscal year were erroneously included on claim requests of the subsequent fiscal year. Cause: The Organization does not accurately accrue expenses at year end. Effect: Costs charged to the Federal award were not consistently recorded in the proper period. This resulted in situations where reimbursements were requested for costs that did not relate to the funding period and are therefore unallowable. Questioned Costs: The total amount of known or likely questioned costs is less than $25,000. Context: We reviewed payroll expenses for July 2019, which included expenses of $6,375 relating to the prior fiscal year. We also noted expenses relating to June 2020 of $5,977 were not claimed during this fiscal year, but in July 2020. The total error nets to $398. Repeat Finding: Yes Recommendation: We recommend that the Organization implement procedures to ensure that all costs that are incurred during the reporting period are properly accrued and charged to the Federal award in the same period. Payroll costs that relate to the reporting period should also be accrued at year end and coded to the specific funding source code. Views of Responsible Officials: See Corrective Action Plan attached.
We have implemented internal control procedures to ensure payroll expenses at fiscal year end reflect the expense to be recorded within the Federal award's budget period. Proper payroll accrual procedures for these expenditures that occurred before fiscal year end will be implemented at fiscal year end to ensure this process.
2019-002
FAC accepted this audit on January 11, 2021 — management decision was due July 11, 2021.
Currently, time sheets are maintained for all employees, but they do not specify actual time spent for each program or function. Time and effort of employees are allocated based on estimates and budget limitations. Cause: Allocation to funding sources were entered in the payroll system based on budget estimates rather than timekeeping reports. Effect: The amount of personal services charged to the Federal award does not meet the documentation requirements outlined in Cost Principles of Uniform Guidance Questioned Costs: None. Alternative controls existed, that while not meeting the federal requirements for documenting salaries, was able to be verified. Context: Timesheets of the Organization do not specify actual time spent on each specific program. However, only 2 employees that were charged to the Federal award performed multiple functions within the Organization. The remaining employees worked 100% on the federal program. Repeat Finding: No Recommendation: We recommend that all personnel use a timesheet to track their actual time spent working on each program and that be used as the basis for recording salary to the books and used as the source of costs that get charged to Federal awards. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴2019-001 ? Activities Allowed/Allowable Costs Program: CFDA# 17.259 ? WIOA Youth Activities Sponsor Award Number: 90535/90536/90537/90538/C18414GG Sponsor Agency: U.S. Department of Labor passed through New York City Department of Youth and Community Development and New York State Department of Labor Criteria: 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 control 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; (v)Comply with the established accounting policies and practices of the non-Federal entity; (vii)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. Citation: 2 CFR 200.430(i) Condition: Currently, time sheets are maintained for all employees, but they do not specify actual time spent for each program or function. Time and effort of employees are allocated based on estimates and budget limitations. Cause: Allocation to funding sources were entered in the payroll system based on budget estimates rather than timekeeping reports. Effect: The amount of personal services charged to the Federal award does not meet the documentation requirements outlined in Cost Principles of Uniform Guidance Questioned Costs: None. Alternative controls existed, that while not meeting the federal requirements for documenting salaries, was able to be verified. Context: Timesheets of the Organization do not specify actual time spent on each specific program. However, only 2 employees that were charged to the Federal award performed multiple functions within the Organization. The remaining employees worked 100% on the federal program. Repeat Finding: No Recommendation: We recommend that all personnel use a timesheet to track their actual time spent working on each program and that be used as the basis for recording salary to the books and used as the source of costs that get charged to Federal awards. Views of Responsible Officials: See Corrective Action Plan attached.
All employees record their time worked on a daily basis via our ADP payroll system. However, we will implement an additional process in our payroll system to allow employees to track their time spent on Federal awards.
We noted transaction that related to the prior fiscal year were erroneously included on claim requests of the current period. Cause: The Organization does not accurately accrue expenses at year end. Effect: Costs charged to the Federal award are not consistently recorded in the proper period. This practice could result in material non-compliance where reimbursements are requested for the costs that are not allowable and do not relate to the funding period. Questioned Costs: The total amount of questioned costs cannot be determined but appears less than $25,000. Context: We tested 55 cash disbursements and noted10 transactions that related to the prior fiscal year. In reviewing all cash disbursements for July 2019, the total population was $16,585. As the maximum exposure falls below the threshold established to report questioned costs, the full population was not examined, and the amount of questioned costs cannot be determined. We reviewed payroll expenses for the first period claimed in July 2019 and saw it included the pay period of the prior fiscal year. The total amount of expenses noted that relates to the prior fiscal year was $6,374. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all costs that are incurred during the reporting period are properly accrued and charged to the Federal award in the same period. Invoices received subsequent to the year-end should be reviewed regularly to ensure they are recognized in the proper period. Payroll costs that relate to the reporting period should also be accrued at year end. Views of Responsible Officials: See Corrective Action Plan attached
Show full finding ▾Hide full finding ▴2019-002 ? Activities Allowed/Allowable Costs Program: CFDA# 17.259 ? WIOA Youth Activities Sponsor Award Number: 90535/90536/90537/90538/C18414GG Sponsor Agency: U.S. Department of Labor passed through New York City Department of Youth and Community Development and New York State Department of Labor Criteria: Expenses must be claimed in the period they were incurred. Citation: 2 CFR 230, 2 CFR 215.28 Condition: We noted transaction that related to the prior fiscal year were erroneously included on claim requests of the current period. Cause: The Organization does not accurately accrue expenses at year end. Effect: Costs charged to the Federal award are not consistently recorded in the proper period. This practice could result in material non-compliance where reimbursements are requested for the costs that are not allowable and do not relate to the funding period. Questioned Costs: The total amount of questioned costs cannot be determined but appears less than $25,000. Context: We tested 55 cash disbursements and noted10 transactions that related to the prior fiscal year. In reviewing all cash disbursements for July 2019, the total population was $16,585. As the maximum exposure falls below the threshold established to report questioned costs, the full population was not examined, and the amount of questioned costs cannot be determined. We reviewed payroll expenses for the first period claimed in July 2019 and saw it included the pay period of the prior fiscal year. The total amount of expenses noted that relates to the prior fiscal year was $6,374. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all costs that are incurred during the reporting period are properly accrued and charged to the Federal award in the same period. Invoices received subsequent to the year-end should be reviewed regularly to ensure they are recognized in the proper period. Payroll costs that relate to the reporting period should also be accrued at year end. Views of Responsible Officials: See Corrective Action Plan attached
We have implemented internal control procedures to ensure expenditures reflect the expense to be recorded within the Federal award?s budget period. Proper accrual procedures for expenditures that occurred before fiscal year end will be implemented at fiscal year end to ensure this process.
FAC accepted this audit on April 1, 2019 — management decision was due October 1, 2019.
FAC accepted this audit on March 18, 2018 — management decision was due September 18, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 20, 2017 — management decision was due September 20, 2017.
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