Criteria: 2 CFR, section 200.430 states, in part:
(i) Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work
performed. These records must:
(vii) 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 cost activity and a 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.
2 CFR, section 200.303 states, in part:
The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
CSAM Procedure 905 states, in part:
Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need
only complete a periodic certification. The periodic certification must: be prepared at least semiannually. Be signed
by the employee or the supervisory official having firsthand knowledge of the work performed by the employee.
State the employee worked solely on that single federal program or cost objective during the period covered by the
certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the
documentation for all employees who worked on the cost objective.
Personnel Activity Report
Except as provided in “Substitute Systems for Time Accounting” employees who work on multiple activities or cost
objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent
documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it
may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost
objective. The level of detail can generally be determined by the diversity and variation of the employee’s work
activities. The safest approach is to provide more documentation rather than less.
Condition: We identified 15 employees whose salaries were charged to Education Stabilization Funds but the
District was unable to provide time accounting documentation for the 2022-23 fiscal year.
Context: Exceptions were discovered in all 15 employees sampled.
Questioned Costs: Total questioned cost for the 15 employees is $66,793.
Cause: The District does not have adequate controls in place to ensure that time certification documentation is
prepared and maintained to support all employees who are paid with federal funds.
Effect: District may be overcharging the Education Stabilization funds for time which isn’t spent directly working
on the program.
Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure
905, which require that employee time certification forms be maintained for employees who charge time to federal
program.
Views of Responsible Officials: Starting April 1, 2024, Keppel Union School District will require all employees
funded by more than one resource to fill out a PAR Form. The District will require those funded by one restricted
resource to be covered by a blanket semi-annual PAR Form.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: 2 CFR, section 200.430 states, in part:
(i) Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work
performed. These records must:
(vii) 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 cost activity and a 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.
2 CFR, section 200.303 states, in part:
The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
CSAM Procedure 905 states, in part:
Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need
only complete a periodic certification. The periodic certification must: be prepared at least semiannually. Be signed
by the employee or the supervisory official having firsthand knowledge of the work performed by the employee.
State the employee worked solely on that single federal program or cost objective during the period covered by the
certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the
documentation for all employees who worked on the cost objective.
Personnel Activity Report
Except as provided in “Substitute Systems for Time Accounting” employees who work on multiple activities or cost
objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent
documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it
may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost
objective. The level of detail can generally be determined by the diversity and variation of the employee’s work
activities. The safest approach is to provide more documentation rather than less.
Condition: We identified 15 employees whose salaries were charged to Education Stabilization Funds but the
District was unable to provide time accounting documentation for the 2022-23 fiscal year.
Context: Exceptions were discovered in all 15 employees sampled.
Questioned Costs: Total questioned cost for the 15 employees is $66,793.
Cause: The District does not have adequate controls in place to ensure that time certification documentation is
prepared and maintained to support all employees who are paid with federal funds.
Effect: District may be overcharging the Education Stabilization funds for time which isn’t spent directly working
on the program.
Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure
905, which require that employee time certification forms be maintained for employees who charge time to federal
program.
Views of Responsible Officials: Starting April 1, 2024, Keppel Union School District will require all employees
funded by more than one resource to fill out a PAR Form. The District will require those funded by one restricted
resource to be covered by a blanket semi-annual PAR Form.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.
Criteria: California Department of education Management Bulletin SNP-27-2015 and CACFP-07-2015 require
educational agencies operating multiple child nutrition programs to separately account for program revenue and
expenses.
Condition: During our review expenditures we discovered that the District does not track expenses separately for
Child Nutrition Program and Child and Adult Care Food Program (CACFP). District does not maintain separate
invoices and they do not have an established interprogram vending agreement. The District only charged the CACFP
program $69,379 in 2022-23 fiscal years, all other expenses were charged to the National School Lunch Program.
Context: Fiscal year 2022-23, occurring in the Cafeteria Fund.
Questioned Costs: Due to the lack of information, auditor is unable to determine the questioned costs.
Cause: The District does not have adequate controls in place to ensure that indirect costs are charged consistently
across the board to all categorical programs.
Effect: Common, shared expenses are not being charged in an equitable, logical manner between the programs.
Recommendation: District should establish an interprogram vending agreement and determine how much the
National School Lunch program was charged and subsequently reimburse the program.
Views of Responsible Officials: Keppel Union School District has been working with consultants and auditors to
establish an interprogram vending agreement to properly move expenses from 53100 to 53200 each month.