EXTERNAL AUDITS LPA Roundtable Event November 2015 Presented by: - - PowerPoint PPT Presentation

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EXTERNAL AUDITS LPA Roundtable Event November 2015 Presented by: - - PowerPoint PPT Presentation

EXTERNAL AUDITS LPA Roundtable Event November 2015 Presented by: Gregory Stephens, Manager Overview 1. Background Information 2. Different types of services and reviews provided o Reasons completed 3. Selection Criteria/Risk Based Criteria


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EXTERNAL AUDITS

Presented by: Gregory Stephens, Manager

LPA Roundtable Event November 2015

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Overview

  • 1. Background Information
  • 2. Different types of services and

reviews provided

  • Reasons completed
  • 3. Selection Criteria/Risk Based Criteria
  • 4. Follow-up – Streamlining
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Oversight Operations required of ODOT

Background Information

  • ODOT must monitor activities under Federal awards.

–to assure compliance with applicable Federal requirements – to assure performance expectations are being achieved.

  • We are also held accountable to the Auditor of

State’s Office.

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Education and Training

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Different types of services/reviews performed by the Office of External Audits

Education and Training

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Education and Training

  • Benefits recognized:

–All participants are more informed. –Training events provide an opportunity to build relationships. –Better understanding of responsibilities. –Fewer findings during audits.

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Requirement Review Form (RRF)

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Different types of services/reviews performed by the Office of External Audits

RRF Advisory Role Education and Training

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Requirement Review Form (RRF) Advisory Role

  • Proposal of the RRF
  • Review of the RRF
  • Provides more assurance for the LPA’s

processes and project documentation.

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Limited Scope Review (LSR)

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Different types of services/reviews performed by the Office of External Audits

Limited Scope Review RRF Advisory Role Education and Training

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Limited Scope Review (LSR) - Background

  • The LSR is not an audit.
  • The LSR is a review of only a subset of audit

requirements.

  • No Formal Report is provided for an LSR.
  • Information is shared with District personnel, Local

Programs and the LPA.

  • Focus of LSR may change as audit risks are identified.
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Limited Scope Review (LSR) - Background

  • Current LSR focus is LPA Labor support.
  • These Limited Scope Reviews focus specifically on time-

tracking and support of labor costs.

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LSR - Payroll Cost Support

  • LPAs and ODOT need to follow Federal standards for

documentation of personnel expenses. –Even though full support of time-tracking must be maintained, ODOT Districts often may not require full-support of time with invoices.

  • LPAs need to charge the actual hourly wage of the

LPA staff working on the project (at the time the hours were worked.)

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LSR Time Tracking - LPA Involvement

  • If the ODOT voucher does not include detail – we

request the support from the District and/or the LPA.

  • We provide feedback to the LPAs on any deficiencies in

its process so that it could make improvements to be eligible for reimbursement in the future.

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LSR – What does ODOT currently review?

Timesheet support for all paid hours in payroll period Payroll support for Employee Base/OT rate Timesheet documents hours worked on each project Employees' time tracked to payroll records Timesheet tracks time daily (work, leave, holiday, sick, etc) Support of Employee status Employee approval of timesheet Date of Employee approval Supervisor approval of timesheet Employee is full-time, with benefits Date of Supervisor approval Overhead method approved for use Supervisor approval, no less than monthly Overhead rates calculated correctly Overtime allocated to all projects Corrections (made in ink and initialed) Time Tracking Payroll Register Overhead Elgibility

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Review and Approval of Fringe and Overhead Rates

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Different types of services/reviews performed by the Office of External Audits

Fringe and Overhead Rate Review Limited Scope Review RRF Advisory Role Education and Training

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Review and Approval of Fringe and Overhead Rates Background

  • Safe Harbor

– Needed no support of costs for the LPA to apply this rate. –Of 300 LPAs receiving Federal funding in 2014, only a few LPAs requested the use of their own approved rate.

  • Fringe and Overhead Rates

–Are now necessary for each LPA to recover fringe or

  • verhead costs.

– Need to be documented and supported with actual incurred costs from the LPA’s accounting system data.

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Review and Approval of Fringe and Overhead Rates - LPA Involvement

  • The LPA is very involved in the process of documenting costs

when considering the costs of the:

– Entire Agency – Engineer’s Office – Specific subset of the Engineer’s Office

  • Role of LPA’s Finance/Auditor’s Office

ODOT LPA External Auditor can help work with the finance staff to explain what documentation is needed and why it’s needed.

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Review of Fringe and Overhead Rates – What does ODOT review?

When reviewing the rate documentation, per Federal requirements, we ensure:

  • The costs included in the form match to the financial system reports.
  • Any allocated costs are allocated to benefitted agencies on some reasonable

basis.

  • The LPA has not exceeded Federal reserve limitations for Self Insurance funds

– Most often includes Health Insurance and/or Workers’ Compensation

  • That only labor costs and only fringe costs related to the personnel identified are

included.

  • That all labor costs and all fringe costs related to the personnel identified are

included.

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Review of LPA Auditor of State Audits

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Different types of services/reviews performed by the Office of External Audits

AOS Audit Review Fringe and Overhead Rate Review Limited Scope Review RRF Advisory Role Education and Training

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Review of LPA AOS Audits - Background

  • LPAs are required by Federal law to have an audit

completed each year or every other year.

– Dependent on the amount of Federal funding expended during the LPA’s fiscal year.

  • ODOT is required, as the pass-through entity, to

review the LPA’s audit results.

– $500,000* over – annually – this audit is referred to as a Single Audit. –Less than $500,000* - Regular audit – may be completed annually or every other year.

*Threshold changed to $750,000 in 2015 with implementation of 2 CFR 200

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LPA AOS Audits - What Does ODOT Review?

  • Did the LPA report all Federal expenditures for the

ODOT Highway Funded Program?

  • Did the LPA have a Single Audit or Regular Audit?
  • Did the AOS identify:

– “Findings” or “Noncompliance” with the ODOT Highway

Funded Program?

  • Material noncompliance or deficiencies in the program

– Management Letter “Findings” or Recommendations?

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Desk Inspection – LPA Involvement

  • We contact the LPA only if:

– Expenditure reporting is not correct.

  • We contact the LPA Auditor/finance contact listed on the Federal Audit

Clearinghouse form.

– There are issues identified that may relate to the Highway Program.

  • We will have to request a corrective action plan.

It is possible to have a good audit with the AOS, and yet have project specific issues identified in an ODOT Project review.

– AOS review is very high-level as it is reviewing all the LPA departments; ODOT is reviewing one specific project.

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Why do we review the LPA AOS audits?

  • Pass-through Entity Responsibilities:

–Monitor financial reports –Request a formal corrective action plan from the LPA –Evaluate Risk

  • Oversight of ODOT:

–FHWA –AOS

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Limited Scope Audit

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Different types of services/reviews performed by the Office of External Audits

Audit AOS Audit Review Fringe and Overhead Rate Review Limited Scope Review RRF Advisory Role Education and Training

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Limited Scope Audit - Background

  • Limited Scope Audits have been performed for many

years.

  • The Limited Scope Audit Program was streamlined in

2014.

–Some of the items no longer reviewed during the Project LSR:

  • DBE
  • Prevailing Wage
  • Specific Item Quantities (3-way match: daily diary to

item delivery tickets to invoiced costs)

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Limited Scope Audit Streamlined

  • The External Auditor now spends less than one day on-site at

each LPA.

  • A project review form is emailed to LPA.
  • External Auditor begins review at ODOT office and follows up
  • n-site with LPA to clarify any outstanding items.
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Limited Scope Audit – Selection Criteria

For those entities selected for audit, the audit file introductory page provides selection criteria: As the Requirement Review form was implemented in 2015, the results from it and the LSR will also become part of the risk criteria in the future.

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Limited Scope Audit – LPA Involvement

  • LPA will be responsible for pulling documentation

and emailing to ODOT.

  • LPA works with ODOT during on-site review.
  • LPA will be required to provide a response to the

audit report.

  • LPA may be required to provide a corrective action

plan.

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Limited Scope Audit – What does ODOT review?

  • Pre-Award

– Person in Responsible Charge, Legislation to enter into project, Bid Documents include FHWA 1273, EPLS

  • Post-Award

– Bid tab, Bid policy, Bid award, 30 percent tracking

  • Daily Diaries

– Includes detail for work completed, equipment used, personnel labor, bid quantities

  • Change Orders

– Change order policy followed, significant change orders identified

  • Consultant and Contractors

– Agreements include FHWA 1273, Correct indirect rate applied to Consultant invoices, Support for Consultant labor

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Limited Scope Audit – What does ODOT review?

  • Project Completion

–Was the final inspection and Final Report completed? –Did the Invoice Reconcile to planned costs?

  • Original bid +/- change orders agree with invoiced costs.

–CE Invoices

  • Does the LPA have a compliant time-tracking system?
  • Did the LPA charge the correct rate and apply the correct cost recovery

method?

–Schedule of Expenditures of Federal Awards (SEFA)

  • Does the LPA have an adequate process for tracking and accurately

reporting its Federal expenditures?

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Summary of all ODOT Reviews

  • Achieve Federal requirements assigned to pass-through agency.
  • Achieve AOS requirements as a Federal pass-through agency.
  • Identify best practices at the Districts and LPAs.
  • Provide LPA with feedback on its processes to ensure

compliance.

  • Provide LPA with the highest, supported, rate to apply to labor

costs.

– Work closely with LPAs to identify other costs that could be documented in the future. – Work closely with LPAs to better understand the requirements and the process.

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Questions or Feedback?