Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173;
Federal Agency – U.S. Department of Education;
Pass-through Agency – New York State Department of Education;
Grant period – July 1, 2022 – June 30, 2023
Condition: The School District did not have a control in place to ensure that there was adequate
documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s
salary among specific activities when an employee worked on both a Federal award and a non-
Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime
equivalent (FTE) time to be allocated to the grant and they were not reviewed.
Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement
indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State
and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a
Federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single Federal program
whose funds have not been consolidated or Federal programs whose funds have been
consolidated but not with State and local funds), an LEA is not required to maintain records
reflecting the distribution of the employee’s salary and wages, including among the Federal
programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
Federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on Federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
i. The Federal program or cost objective; and
ii. Each other program or cost objective supported by consolidated Federal funds or
other revenue sources.
Cause: There was turnover in the Chief Executive Director of HR & Grants Management position,
and as such, there was no position clearly tasked with the responsibility of reviewing the Certification
of Federal Award forms during the year.
Effect: The School District could have claimed grant reimbursement for an employee when the
employee may not have actually worked hours related to, or allowable under, that program.
Context: The School District indicated that the Certification of Federal Award forms were not
reviewed for any of the employees charged to the grants under the Special Education Cluster.
Auditor’s Recommendation: The School District should implement a process in which employee’s
time is documented on the Certification of Federal Award forms and the forms are reviewed by an
individual with sufficient knowledge about the employee’s duties and the Federal program in order to
ensure the costs are allowable and adequately documented.
View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of
Curriculum & Instruction will work with the Business office and the Human Resources department to
ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged
to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.