Audit 301414

Title I Grants to Local Educational Agencies ConditionDuring our audit it was determined that the required Time and Effort Documentation was not accurately maintained by the Clay County Board of Education Title I Department in regards to employees funded under the Federal Title I grants applicable to the Title I Grants to Local Educational Agencies, AL #84.010. More specifically, the Time and Effort Documentation was not maintained as required for two employees who are required to make certifications of their time and effort. Criteria: OMB Circular A-87 provides detailed rules on the use of federal funds. Attachment B – Section 8h states the following: h. Support of salaries and wages. These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for the salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first hand knowledge of the work performed by the employee. (4) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation, which meets the standards in subsection (5) unless a statistical sampling system (see subsection(6)) or other substitute system has been approved by the cognizant Federal agency. Such documentary support will be required where employees work on: a) More than one Federal award, b) A Federal award and a non Federal award, c) An indirect cost activity and a direct cost activity, d) Two or more indirect activities which are allocated using different allocation bases, or e) An unallowable activity and a direct or indirect cost activity. Cause: Management of the Title I Department did not have proper procedures in place to ensure that certifications and/or the reporting of Time and Effort Documentation was accurately maintained as required. Effect: As a result of not adequately maintaining the Time and Effort Documentation for employees paid with federal funding, the Title I Department of the Clay County Board of Education was not in compliance with the requirement of maintaining adequate documentation under OMB Circular A-87. Identification of Repeat Findings, if Applicable: This condition was not reported in the prior year's audit. Recommendation: We recommend that the Clay County Board of Education's Title I Department implement procedures to accurately document and maintain the Time and Effort Documentation of all employees funded with federal funding, as required. Views of Responsible Officials and Planned Corrective Action: The Title I Department of the Clay County Board of Education will implement procedures to ensure that "Time and Effort" Documentation and records are adequately maintained, as required for all applicable employees. Total Questioned Costs -0-

Title I Grants to Local Educational Agencies ConditionDuring our audit it was determined that the required Time and Effort Documentation was not accurately maintained by the Clay County Board of Education Title I Department in regards to employees funded under the Federal Title I grants applicable to the Title I Grants to Local Educational Agencies, AL #84.010. More specifically, the Time and Effort Documentation was not maintained as required for two employees who are required to make certifications of their time and effort. Criteria: OMB Circular A-87 provides detailed rules on the use of federal funds. Attachment B – Section 8h states the following: h. Support of salaries and wages. These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for the salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first hand knowledge of the work performed by the employee. (4) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation, which meets the standards in subsection (5) unless a statistical sampling system (see subsection(6)) or other substitute system has been approved by the cognizant Federal agency. Such documentary support will be required where employees work on: a) More than one Federal award, b) A Federal award and a non Federal award, c) An indirect cost activity and a direct cost activity, d) Two or more indirect activities which are allocated using different allocation bases, or e) An unallowable activity and a direct or indirect cost activity. Cause: Management of the Title I Department did not have proper procedures in place to ensure that certifications and/or the reporting of Time and Effort Documentation was accurately maintained as required. Effect: As a result of not adequately maintaining the Time and Effort Documentation for employees paid with federal funding, the Title I Department of the Clay County Board of Education was not in compliance with the requirement of maintaining adequate documentation under OMB Circular A-87. Identification of Repeat Findings, if Applicable: This condition was not reported in the prior year's audit. Recommendation: We recommend that the Clay County Board of Education's Title I Department implement procedures to accurately document and maintain the Time and Effort Documentation of all employees funded with federal funding, as required. Views of Responsible Officials and Planned Corrective Action: The Title I Department of the Clay County Board of Education will implement procedures to ensure that "Time and Effort" Documentation and records are adequately maintained, as required for all applicable employees. Total Questioned Costs -0-