Audit 19283

2 CFR ? 3474.1 gives regulatory effect to the Office of Management and Budget Guidance in 2 CFR part 200, adopted by the Department of Education. 2 CFR ? 200.430 states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; be incorporated into the official records of the non-Federal entity; and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. District Policy 6116 for Time and Effort Reporting indicates the reports should 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 and 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. The payroll office is responsible for the distribution, collection, and retention of all employee time and effort reports. The salaries for 22/22 employees tested were charged to the Title I Grant Fund without any time and effort documentation maintained to support the amount of time worked on the grant. Therefore, we consider the salaries and related benefits for these employees in the amount of $335,270 to be a questioned cost. Failure to maintain the appropriate time and effort documentation could lead to future questioned costs, reduced future federal funding, and the requirement to repay the Ohio Department of Education. The District should ensure all employees charging salaries and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with District Policy 6116 ? Time and Effort Reporting. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or timesheets when an employee works on multiple activities.

2 CFR ? 3474.1 gives regulatory effect to the Office of Management and Budget Guidance in 2 CFR part 200, adopted by the Department of Education. 2 CFR ? 200.430 states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both Federal and non-Federal activities. In addition, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; be incorporated into the official records of the non-Federal entity; and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. District Policy 6116 for Time and Effort Reporting indicates the reports should 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 and 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. The payroll office is responsible for the distribution, collection, and retention of all employee time and effort reports. The salaries for 22/22 employees tested were charged to the Title I Grant Fund without any time and effort documentation maintained to support the amount of time worked on the grant. Therefore, we consider the salaries and related benefits for these employees in the amount of $335,270 to be a questioned cost. Failure to maintain the appropriate time and effort documentation could lead to future questioned costs, reduced future federal funding, and the requirement to repay the Ohio Department of Education. The District should ensure all employees charging salaries and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with District Policy 6116 ? Time and Effort Reporting. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or timesheets when an employee works on multiple activities.