EIN: 823383533
UEI: Q9UHVXV5R7D1
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2021. 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 30, 2021, which was (1784 days ago).
What is a management decision? →Condition During our audit of Concourse for the year ended June 30, 2020, we examined 12 personnel files on a sample basis and identified the following exceptions: ? 1 file did not document wage rate in the personnel file. Criteria In accordance with New York State Department of Labor Law included in the Wage Theft Prevention Act (WTPA), New York employers, such as Concourse, should provide their employees with written notice of wage rates and method of payment (i.e. hourly), at the time of hire and annually thereafter before February 1. Cause Personnel files were not reviewed for completeness of required documentation. Effect Noncompliance with New York State and New York City labor law. Recommendation Concourse should designate management level personnel (the Payroll Manager) as responsible for assembling a complete personnel file for a new hire in addition to the ongoing monitoring of all existing personnel files to ensure compliance with labor law. This procedure should be systematized, and designated oversight should be documented by completing a comprehensive checklist upon hire and before the beginning of the following calendar year. These procedures should be integrated with the new system already adopted with the payroll provider that requires a complete personnel file monitored for compliance with labor policies and law before processing payroll for a new hire. Management?s Response Management agrees with the recommendation and Concourse is in the process of correcting the deficiencies identified above. Please see management?s Corrective Action Plan attached to this report.
Management has implemented the usage of an HRIS database system through its payroll processing company. The implementation of this software has greatly improved our record keeping in many aspects but specifically in the area of personnel files. Prior to FY20, much of our record keeping including personnel files was done manually and via paper and physical files. With the implementation of the HRIS system, recordkeeping has been streamlined to an electronic format. In this format, all employee documents are stored electronically in the database and are readily available at the click of a button. Additionally, crucial steps have been added to the electronic onboarding process to ensure that employees cannot continue with their onboarding without the execution of a number of documents including the pay rate form. Further, more documents have been added to the hiring process including an offer letter. This will ensure that salary is clearly indicated from the start of employment. This will assist management in the tracking and permanent storage of required employee personnel documents. Going forward, Management commits to leveraging the newly implemented HRIS system to ensure that required documents remain permanently in all employee files.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2020. 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 March 29, 2021, which was (1969 days ago).
What is a management decision? →Condition At June 30, 2019, Concourse had not accrued payroll and related payroll taxes incurred for the period 6/24/19 to 6/30/19 amounting to $19,693. Criteria Accounting principles generally accepted in the United States of America (U.S. GAAP) require the accrual of expenses incurred but not paid at the statement of financial position date. Cause Management recognized payroll and related payroll taxes as paid on a biweekly basis and did not recognize the portion of the biweekly payroll incurred and unpaid at the statement of financial position date. Effect Recognizing expenses incurred prior to the statement of financial position date only after that date when paid is a departure from U.S. GAAP. Recommendation Concourse should provide for the accrual at the statement of financial position date of all significant costs and obligations incurred by that date, including payroll and related payroll taxes. Management?s Response Management has approved and posted the auditor?s proposed adjustment of $19,693 to recognize the unpaid portion of the biweekly payroll and related payroll taxes incurred at June 30, 2019 and has engaged the auditor to calculate the payroll accrual subject to its oversight and approval. Management would like to note that adjusting entries for accrual purposes interferes with the cash basis reporting requirements of the pass-through entity, HRA/DHS.
Adjusting entries for accrual purposes interferes with the cash basis reporting requirements of the funding source, New York City?s Department of Homeless Services. In order to properly close-out a fiscal year by the standards of DHS in conjunction with all applicable requirements, adjusting entries for accrual purposes cannot be made until after final close-out invoices have been submitted. Going forward, Management will not engage with the auditing firm until the fiscal year has been fully closed out with DHS. This will eliminate the barrier with the addition of adjusting entries for accruals and will allow Management to add the required entries without interference with reporting to the City of New York.
Condition During our audit of Concourse during the eighteen-month period January 1, 2018 through June 30, 2019, we examined 12 personnel files on a sample basis and identified the following exceptions: ? 7 files did not document the employee?s health insurance enrollment. ? 2 files did not document wage rate in personnel file. ? For 1 employee selected, the rate paid per hour per the payroll register selected was less than the $13.00 hourly minimum wage rate required by New York City for employers with 11 or more employees for the applicable period. Criteria In accordance with New York State Department of Labor Law included in the Wage Theft Prevention Act (WTPA), New York employers, such as Concourse, should provide their employees with written notice of wage rates and method of payment (i.e. hourly), at the time of hire and annually thereafter before February 1. Additionally, employees are required to be paid at least the minimum hourly wage stipulated by state (New York) and local (NYC) authorities. Cause Personnel files not reviewed for completeness of required documentation and compliance with minimum hourly wage rates required by state and local authorities. Effect Noncompliance with New York State and New York City labor law. Recommendation Concourse should designate management level personnel (the Payroll Manager) as responsible for processing and approving appropriate new hire terms and rates in addition to ongoing monitoring of all personnel files to ensure compliance with documentation and wage rates required by labor law. This procedure should be systematized and designated oversight should be documented by completing a comprehensive checklist upon hire and before the beginning of the following calendar year. These procedures should be integrated with the new system already adopted with the payroll provider that requires a complete personnel file monitored for compliance with labor policies and law before processing payroll for a new hire. Management?s Response Management agrees with the recommendation and Concourse is in the process of correcting the deficiencies identified above. Please see management?s Corrective Action Plan attached to this report.
Management has implemented the usage of an HRIS database system through its payroll processing company. The implementation of this software has greatly improved our record keeping in many aspects but specifically in the area of personnel files. Prior to FY20, much of our record keeping including personnel files was done manually and via paper and physical files. With the implementation of the HRIS system, recordkeeping has been streamlined to an electronic format. In this format, all employee documents are stored electronically in the database and are readily available at the click of a button. This will assist management in the tracking and permanent storage of required employee personnel documents. Going forward, Management commits to leveraging the newly implemented HRIS system to ensure that required documents remain permanently in all employee files.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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