Again, the OIG is trying to micromanage MFET operations on a retrospective basis. However, had MFET not taken this corrective action to improve performance, the DOL would have cited MFET on poor performance. Since the overall suspension was exercised, OIG states each case should have been done on a case-by-case basis. MFET believes that this was a reasonable action in that a prudent person has a responsibility to DOL and clients for performance and staff for continued funding based on performance.

The OIG is incorrect in stating that leave was uniformly suspended ". . . including those employees who had no impact whatsoever on improving program performance." All staff does have impact on performance which is what MFET was trying to establish by working for its goals on a "team" basis. Any employee with "no input on performance" would indicate no need for the position.

The statements made by OIG regarding permitting annual leave only in 4 hour increments, and requiring employees to report to work to prove his/her illness prior to approving sick leave are completely false. MFET does require, in its sick leave policies, that each day an employee is out for an illness he/she must inform his/her supervisor. This is to ensure that arrangements can be made for coverage of the office and any appointments which might have been made.

employees told us that they viewed these restrictions as an abuse of power by MFET's top management. MFET's response on whether leave requests should have been examined on a case-by-case basis is somewhat confusing. In a written response, MFET stated that perhaps MFET could have exercised this prerogative on a case-by-case basis and accomplished the same objective. Continuing, MFET stated that management exercised its best judgment and decided to be up front with all employees and in an effort to achieve goals through a team effort, all employees were informed of the suspension of annual leave for all employees. In a later response, MFET states that it has provided examples to show that leave requests were analyzed on a case-by-case basis. MFET later states that, had MFET not taken the corrective action (the suspension of leave) to improve program performance, the DOL would have cited MFET on poor performance. Nevertheless, as stated previously, we recognize that MFET's management has a right to balance organizational goals and objectives with employee wishes/needs in the course of approving leave. However, we believe that MFET should have exercised this decision to approve leave on a case-by-case basis instead of uniformly suspending leave for all employees. We continue to believe that the 90-day suspension of annual leave was a major contributing factor to employees losing significant amounts of annual leave at the end of the leave year. Because of the 90-day suspension on the use of annual leave, we believe MFET should have held the employees harmless by allowing the effected employees, on this one-time basis, to carry over their unused (lost) annual leave into the next leave year.
 

RECOMMENDATION 4.        We recommend that the Grant Officer direct MFET to reimburse its employees            for: (a) the $10,716 that was involuntarily contributed for the purpose of lobbying            for farmworker legislation, and (b) the value of the annual leave lost due to the            unnecessary restrictions imposed by MFET.

Questioned Salary Expenses While on Personal Travel
 

Questioned Salary Expenses While on Personal Travel (Cont'd)
 

Questioned M&IE Expenses While on Personal Travel
 

Questioned M&IE Expenses While on Personal Travel (Cont'd)
 

Questioned Lodging and Rental Car Expenses while on Personal Travel
 

 
 

NAME	1992	1993	1994	1995	1996	TOTAL
Employee #1	$5.00					$5.00
Employee #2	26.00					26.00
Employee #3	20.00					20.00
Employee #4	25.00					25.00
Employee #5	42.00					42.00
Employee #6	34.00					34.00
Employee #7	18.00					18.00
Employee #8	9.00					9.00
Employee #9		$17.00				17.00
Employee #10		24.00				24.00
Employee #11		15.00				15.00
Employee #12		26.00	$26.00	$130.00		182.00
Employee #13		69.00				69.00
Employee #14		40.00				40.00
Employee #15		26.00	3.00			29.00
Employee #16		14.00				14.00
Employee #17		52.00				52.00
Employee #18		14.00				14.00
Employee #19		26.00	26.00	208.00	$112.00	372.00
Employee #20		130.00	150.00	260.00	140.00	680.00
Employee #21		26.00	30.00	55.00		111.00
Employee #22		78.00	78.00	78.00	42.00	276.00
Employee #23		40.00				40.00
Employee #24		26.00	34.00	130.00	70.00	260.00
Employee #25		26.00	8.00			34.00
Employee #26		5.00				5.00

NAME	1992	1993	1994	1995	1996	TOTAL
Employee #27		$24.00				$24.00
Employee #28		270.00	$690.00	$560.00		1,520.00
Employee #29		26.00	30.00	130.00	$70.00	256.00
Employee #30		26.00	38.00	104.00	56.00	224.00
Employee #31			3.00	37.00		40.00
Employee #32			28.00	182.00	98.00	308.00
Employee #33			28.00	182.00	98.00	308.00
Employee #34			3.00	23.00		26.00
Employee #35			23.00	130.00	70.00	223.00
Employee #36			20.00	65.00		85.00
Employee #37			1.00	90.00	30.00	121.00
Employee #38			20.00	130.00	120.00	270.00
Employee #39			20.00	80.00		100.00
Employee #40			6.00	52.00	28.00	86.00
Employee #41			40.00	260.00	140.00	440.00
Employee #42			9.50	52.50		62.00
Employee #43			3.00	5.00		8.00
Employee #44			40.00	260.00	30.00	330.00
Employee #45			6.00	52.00	28.00	86.00
Employee #46			5.00			5.00
Employee #47			5.00	130.00	20.00	155.00
Employee #48			30.00			30.00
Employee #49			5.00	27.00		32.00
Employee #50			3.00	51.00	22.00	76.00
Employee #51			28.00	112.00		140.00
Employee #52			20.00	130.00	70.00	220.00
Employee #53			20.00	130.00	70.00	220.00

NAME	1992	1993	1994	1995	1996	TOTAL
Employee #54			$40.00	$260.00	$140.00	$440.00
Employee #55			31.00	325.00	182.00	538.00
Employee #56			20.00	130.00	70.00	220.00
Employee #57			24.00	78.00		102.00
Employee #58			30.00	220.00	50.00	300.00
Employee #59			5.50	11.00		16.50
Employee #60			15.00	105.00		120.00
Employee #61				130.00	70.00	200.00
Employee #62				8.00	28.00	36.00
Employee #63				2.00	13.00	15.00
Employee #64				10.00	40.00	50.00
Employee #65				19.00	8.00	27.00
Employee #66				80.00		80.00
Employee #67				81.00		81.00
Employee #68				4.00	1.00	5.00
Employee #69					4.00	4.00
Employee #70					45.00	45.00
Employee #71					13.00	13.00
Employee #72					30.00	30.00
Employee # 73					70.00	70.00
Employee # 74					120.00	120.00
Employee #75					50.00	50.00
Employee #76					30.00	30.00
Employee #77					15.00	15.00
Totals	$179.00	$1,000.00	$1,645.00	$5,298.50	$2,293.00	$10,415.50

1. DOL's Regional Cost Negotiator established MFET's "Final" Indirect Cost Rates for the years under audit. The Indirect Cost Agreement states that the indirect costs and indirect cost rates "are subject to audit." As a result, any direct costs disallowed by the ETA Grant Officer that, instead, should have been charged as indirect costs will affect the indirect cost rate and resulting amounts of indirect costs allocated/charged to the DOL grants. As such, the DOL Regional Cost Negotiator will need to revise MFET's overhead pools to include the $60,507. This will result in approximately $46,000 of additional allowable indirect costs, as the three grants represent about 75% of MFET's total indirect costs.

2. We identified that MFET charged improper costs totaling $131,392 to its indirect cost pools and recommended that the indirect cost pools be reduced accordingly. As such, the amount of accepted and questioned administrative costs may vary depending on any adjustments to MFET's indirect cost rates.

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