WESTCHESTER JEWISH COMMUNITY SERVICES, INC.

Finding 2025-002, Accuracy of the SEFA Criteria: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee’s financial statements. At a minimum, the schedule shall: • List all individual Federal programs by Federal agency. • Include the name of the pass-through entity and the identifying number assigned by the passthrough entity for all Federal funds expended as a subrecipient. • Provide the total Federal awards expended for each individual Federal program and the Assistance Listing Number or other identifying number when the Assistance Listing Number information is not available. Condition and Context: During the audit, we were provided with the SEFA. The SEFA included 100% of expenditures for each grant, even if the grant was not 100% federally funded. Proper identification of federal funds and their related allocations is critical to ensure compliance with federal requirements and accurate reporting. Management subsequently reviewed the funding allocations and revised the SEFA during the audit to properly reflect only the federally funded portion of expenditures. The final SEFA included in the financial statements reflects these corrections. Cause: Internal controls over the accurate preparation and completeness of the preliminary SEFA were not operating effectively. Effect: The SEFA was misstated as initially prepared. Identification as a repeat finding: No. Questioned costs: None. Recommendation: We recommend that the Agency expand its SEFA preparation procedures to identify specific staff responsibilities for the preparation, review and approval of the SEFA. Consideration should be given to creating a master list of all foundation and government grants, and the determination of whether a grant includes federal funding be determined at the onset of the grant (if applicable, at the time that the grant application is submitted). Further, WJCS should implement a process to review and reconcile federal fund allocations, ensuring that the SEFA reflects only the federal portion of each grant, and that all amounts are accurately reported. View of responsible officials: Management acknowledges the importance of accurately reporting only the federal portion of grant expenditures in the SEFA. To address this, management is implementing enhanced procedures. During the current year, a master grants listing was developed to strengthen the grants onboarding process. As part of this process, the team will determine the federal funding details at the outset of each award, when not clearly specified in the contract, and will proactively contact funders to obtain the Assistance Listing Number (ALN)/Catalog of Federal Domestic Assistance (CFDA) number and related information. In addition, federal funding allocation percentages will be appropriately identified, calculated and reported on the SEFA. These actions are expected to improve accuracy and compliance with federal requirements.

Finding 2025-003, Timesheet – Timekeeping (Assistance Listing 16.575 and 93.958) Criteria: 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on records that accurately reflect the work performed, prepared after-the-fact, and includes the total activity for which employees were compensated. Condition and Context: The timesheets used by the Agency through December 2024 did not include the allocation of hours worked by program. Cause: Internal controls over the accurate distribution of hours on the timesheets were not operating effectively or designed properly. Effect: The timesheets do not support the allocation of time charged to the programs. Identification as a repeat finding: Yes. Questioned costs: None. Recommendation: We recommend that the Agency strengthen its policies and procedures for the timekeeping and distribution of the employees’ hours in accordance with the requirements of the federal programs. View of responsible officials: In January 2025, WJCS implemented an automated time and attendance system for staff to track time which integrates with the payroll and financial systems to ensure appropriate allocations to Federal awards. Prior to implementation of the new system, weekly manual timesheets were used to track staff time and attendance on federal contracts. However, these manual timesheets were not integrated into a standard agency-wide payroll processing system. The new system enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations.

Finding 2024-001, Expense Allocations - Financial Management (Assistance Listing 16.575) Criteria: Per 2 CFR § 200.302(a) (Financial Management), all recipient and subrecipient financial management systems must be sufficient to track expenditures and establish that funds have been used in accordance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and Context: The Agency’s general ledger for the program included occupancy expenses that were not used for the program. Although these expenses were erroneously recorded in the general ledger under the program, they were correctly excluded from the submitted claims. Cause: These expenses were incorrectly allocated in the general ledger due to weaknesses in internal controls over expense classification and allocation. The financial management system lacked adequate review mechanisms to ensure expenses were properly assigned to the correct program and reconciled with the submitted claims. Effect: The misallocation of expenses in the general ledger resulted in financial reports that do not accurately reflect actual program expenditures. This misstatement could impact budgetary decisions, financial reporting accuracy, and overall compliance with federal regulations. Identification as a Repeat Finding: No. Questioned Costs: None. Recommendation: We recommend that the Agency strengthen its policies and procedures for expense allocation by implementing a more structured review and approval process. This should include enhanced internal controls, periodic reconciliations of expenses between the general ledger and submitted claims, and staff training on accurate cost classification. Additionally, management should establish clear documentation procedures to support the proper allocation of expenses in the general ledger and ensure compliance with federal regulations.

Finding 2024-002, Timesheet – Timekeeping (Assistance Listing 16.575 and 93.696) Criteria: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Condition and Context: The Agency’s current timesheet does not include the allocation of hours worked by program. Cause: Internal controls over the accurate distribution of hours on the timesheets were not operating effectively or designed properly. Effect: The timesheets do not support the allocation of time charged to the programs. Identification as a repeat finding: Yes. Questioned costs: None. Recommendation: We recommend that the Agency strengthen its policies and procedures for the timekeeping and distribution of the employees’ hours in accordance with the requirements of the federal programs.

Finding 2024-003, Unallowable Expense (Assistance Listing 93.696) Criteria: Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the program. Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic, requires that costs allocated to the program meet these criteria to ensure compliance with federal regulations. Condition and Context: During our testing of the Agency’s expenses charged to the program, we noted one item out of ten items tested that did not relate to the federal program. Cause: The expense was incorrectly allocated to the program due to misclassification or inadequate review during the allocation process. Internal controls designed to ensure proper expense classification were either insufficient or not effectively implemented, leading to the incorrect charge. Effect: Although the expense was charged to the federal program, it was not allowable under the program’s cost principles, resulting in noncompliance with federal regulations. If not addressed, this could lead to inaccurate financial reporting and potential disallowance of costs. Identification as a Repeat Finding: No. Questioned Costs: None. Recommendation: We recommend that the Agency enhance its internal controls over expense allocation by implementing a more structured review and approval process. This should include enhanced staff training on cost allowability, periodic reconciliations of expenses to program requirements, and management oversight to ensure compliance with federal regulations. Additionally, the Agency should establish clear documentation procedures to verify and support the appropriateness of charges to the program before expenses are recorded.

Finding 2024-004, Documentation of Case Note Review (Assistance Listing 16.575) Criteria: Per 2 CFR § 200.303(a) (Internal Controls). All recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition and Context: The Agency’s maintains client case notes to track the services provided to program participants. These case notes are subject to periodic reviews by a Supervisor. We reviewed 25 samples and noted no documentation the review for any of the samples. Cause: The Agency’s policies for maintaining case notes do not require a sign-off by the Supervisor. Effect: The lack of documented supervisory review weakens internal controls over case note management, increasing the risk of errors, incomplete records, or noncompliance with program requirements. Identification as a Repeat Finding: No. Questioned Costs: None. Recommendation: We recommend that the Agency enhance its policies and procedures for case note management by implementing a formal supervisory review process. This should include a documented sign-off by the supervisor to confirm the review has been completed, ensuring compliance with internal control requirements.

Finding 2023-001, Timesheet – Timekeeping (Assistance Listing 93.829) Criteria: The federal program 93.829 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Condition and Context: The Agency’s current timesheet does not include the allocation of hours worked by program. Cause: Internal controls over the accurate distribution of hours on the timesheets were not operating effectively or designed properly. Effect: The timesheets do not support the allocation of time charged to the programs. Identification as a repeat finding: Yes. Questioned costs: None. Recommendation: We recommend that the Agency strengthen its policies and procedures for the timekeeping and distribution of the employees’ hours in accordance with the requirements of the federal programs. View of responsible officials: WJCS implemented weekly manual timesheets to track staff time and attendance on Federal contracts. These timesheets are used to appropriately allocate salaries and wages to federal awards. However, these timesheets are not integrated into a standard agency-wide payroll processing system. In automated systems, timesheets are embedded in an organization’s time and attendance and payroll system. In the first quarter of 2023 WJCS commenced the process of assessing system options and to implement an agency-wide time and attendance system for all WJCS employees. This includes working with our existing payroll processor, and engaging payroll consultants to ensure comprehensive timekeeping, including maintaining the allocation of hours worked by program for all employees. Utilizing these enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations.

Criteria: The federal programs 93.829 require that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Condition and Context: The Agency?s current timesheet does not include the allocation of hours worked by program. Cause: Internal controls over the accurate distribution of hours on the timesheets were not operating effectively or designed properly. Effect: The timesheets do not support the allocation of time charged to the programs.

Criteria: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee?s financial statements. At a minimum, the schedule shall: ? List all individual Federal programs by Federal agency. ? Include the name of the pass-through entity and the identifying number assigned by the passthrough entity for all Federal funds expended as a subrecipient. ? Provide the total Federal awards expended for each individual Federal program and the Assistance Listing Number or other identifying number when the Assistance Listing Number information is not available. Condition and Context: The Agency?s current policies and procedures on the preparation of the SEFA were not detailed enough to ensure all funds were identified as either non-federal, federal, or pass-through federal awards, which resulted in the SEFA provided to the auditors to not accurately reflect certain federal expenditures and Assistance Listing Number information. Cause: Internal controls over the accurate preparation and completeness of the SEFA were not operating effectively. Effect: Delays in identifying whether an award is federally funded could result in errors in accounting, and revenue recognition, disallowed costs, and noncompliance with Uniform Guidance requirements.

Criteria: The federal programs 93.243 and 93.829 require that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, that include the total activity for which employees were compensated. Condition and Context: The Agency?s current timesheet does not include the allocation of hours worked by program. Cause: Internal controls over the accurate distributions of hours on the timesheets were not operating effectively. Effect: The timesheets do not support the allocation of time charged to the program.

Criteria: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee?s financial statements. At a minimum, the schedule shall: ? List all individual Federal programs by Federal agency. ? Include the name of the pass-through entity and the identifying number assigned by the passthrough entity for all Federal funds expended as a subrecipient. ? Provide the total Federal awards expended for each individual Federal program and the Assistance Listing Number or other identifying number when the Assistance Listing Number information is not available. Condition and Context: The Agency?s current policies and procedures on the preparation of the SEFA were not detailed enough to ensure all funds were identified as either non-federal, federal or pass-through federal awards, which resulted in the SEFA provided to the auditors to not accurately reflect certain federal expenditures and Assistance Listing Number information. Cause: Internal controls over the accurate preparation and completeness of the SEFA were not operating effectively. Effect: Delays in identifying whether an award is federally funded could result in errors in accounting, revenue recognition, disallowed costs, and noncompliance with Uniform Guidance requirements.