2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.430 which 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; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; and 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.
Service Center 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 Service Center did not follow policy 6116 relating to time and effort resulting in the following errors:
• The wages and related benefits for four out of 40 employee payroll checks tested totaling $2,569 were charged to the Special Education Grant Fund without any time and effort documentation. Semi-Annual Certifications, Personnel Activity Reports (PARs), or a Substitute System were not maintained to support the amount of time worked on the grant. Therefore, we consider the wages and related benefits for these employees in the amount of $2,569 to be questioned costs.
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 and Workforce.
The Service Center should ensure all employees charging wages and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with the Service Center’s policy. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or personal activity reports or timesheets with sufficient detail when an employee works on multiple activities.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.430 which 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; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; and 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.
Service Center 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 Service Center did not follow policy 6116 relating to time and effort resulting in the following errors:
• The wages and related benefits for four out of 40 employee payroll checks tested totaling $2,569 were charged to the Special Education Grant Fund without any time and effort documentation. Semi-Annual Certifications, Personnel Activity Reports (PARs), or a Substitute System were not maintained to support the amount of time worked on the grant. Therefore, we consider the wages and related benefits for these employees in the amount of $2,569 to be questioned costs.
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 and Workforce.
The Service Center should ensure all employees charging wages and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with the Service Center’s policy. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or personal activity reports or timesheets with sufficient detail when an employee works on multiple activities.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for the Procurement Standards in 2 CFR §§ 200.318 - 200.327. The Procurement Standards require entities to have and use their own documented procurement procedures, consistent with applicable State and local laws and regulations and the standards of 2 CFR 200.318 - .327, for the acquisition of property or services required under a Federal award or subaward. A non-Federal entity must, in part:
1. Meet the general procurement standards in 2 CFR 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR 200.320(a)(1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history, or other information and documents it files accordingly (2 CFR 200.320(a)(1)(ii)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(a)(2)(i)).
4. For acquisitions exceeding the simplified acquisition threshold, the non-Federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(b)(1); the competitive proposals method under the conditions specified in 2 CFR 200.320(b)(2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of five circumstances are met, in accordance with 2 CFR 200.320(c).
Additionally, Service Center Policy 6325 - Procurement indicates procurement of all supplies, materials, equipment, and services paid for from Federal funds or Educational Service Center matching funds shall be made in accordance with all applicable Federal, State, and local statutes and/or regulations, the terms and conditions of the Federal grant, Governing Board policies, and administrative procedures.The Service Center did not follow the federal procurement requirements and policy 6325 relating to procurement resulting in the following errors:
• For six of six tested expenditures that were subject to procurement, the Service Center could not produce support that these expenditures complied with federal procurement requirements and Service Center policy. Five of these expenditures were below the micro-purchase threshold in which the Service Center should have documented and maintained support that the price was reasonable. The remaining expenditure was a small purchase in which the Service Center should have documented and maintained price or rate quotations from an adequate number of qualified sources.
Failure to maintain the appropriate procurement documentation could lead to future findings, reduced federal funding and the requirement to repay the Ohio Department of Education.
The Service Center should ensure appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types. Appropriate supporting documentation could include copies of internet searches or other documented research for micro-purchases and documentation for price or rate quotations from an adequate number of qualified sources for small purchases.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for the Procurement Standards in 2 CFR §§ 200.318 - 200.327. The Procurement Standards require entities to have and use their own documented procurement procedures, consistent with applicable State and local laws and regulations and the standards of 2 CFR 200.318 - .327, for the acquisition of property or services required under a Federal award or subaward. A non-Federal entity must, in part:
1. Meet the general procurement standards in 2 CFR 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR 200.320(a)(1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history, or other information and documents it files accordingly (2 CFR 200.320(a)(1)(ii)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(a)(2)(i)).
4. For acquisitions exceeding the simplified acquisition threshold, the non-Federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(b)(1); the competitive proposals method under the conditions specified in 2 CFR 200.320(b)(2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of five circumstances are met, in accordance with 2 CFR 200.320(c).
Additionally, Service Center Policy 6325 - Procurement indicates procurement of all supplies, materials, equipment, and services paid for from Federal funds or Educational Service Center matching funds shall be made in accordance with all applicable Federal, State, and local statutes and/or regulations, the terms and conditions of the Federal grant, Governing Board policies, and administrative procedures.The Service Center did not follow the federal procurement requirements and policy 6325 relating to procurement resulting in the following errors:
• For six of six tested expenditures that were subject to procurement, the Service Center could not produce support that these expenditures complied with federal procurement requirements and Service Center policy. Five of these expenditures were below the micro-purchase threshold in which the Service Center should have documented and maintained support that the price was reasonable. The remaining expenditure was a small purchase in which the Service Center should have documented and maintained price or rate quotations from an adequate number of qualified sources.
Failure to maintain the appropriate procurement documentation could lead to future findings, reduced federal funding and the requirement to repay the Ohio Department of Education.
The Service Center should ensure appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types. Appropriate supporting documentation could include copies of internet searches or other documented research for micro-purchases and documentation for price or rate quotations from an adequate number of qualified sources for small purchases.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.430 which 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; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; and 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.
Service Center 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 Service Center did not follow policy 6116 relating to time and effort resulting in the following errors:
• The wages and related benefits for four out of 40 employee payroll checks tested totaling $2,569 were charged to the Special Education Grant Fund without any time and effort documentation. Semi-Annual Certifications, Personnel Activity Reports (PARs), or a Substitute System were not maintained to support the amount of time worked on the grant. Therefore, we consider the wages and related benefits for these employees in the amount of $2,569 to be questioned costs.
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 and Workforce.
The Service Center should ensure all employees charging wages and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with the Service Center’s policy. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or personal activity reports or timesheets with sufficient detail when an employee works on multiple activities.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.430 which 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; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; and 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.
Service Center 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 Service Center did not follow policy 6116 relating to time and effort resulting in the following errors:
• The wages and related benefits for four out of 40 employee payroll checks tested totaling $2,569 were charged to the Special Education Grant Fund without any time and effort documentation. Semi-Annual Certifications, Personnel Activity Reports (PARs), or a Substitute System were not maintained to support the amount of time worked on the grant. Therefore, we consider the wages and related benefits for these employees in the amount of $2,569 to be questioned costs.
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 and Workforce.
The Service Center should ensure all employees charging wages and benefits to federal grants maintain the appropriate documentation supporting the time spent on the grant, in accordance with the Service Center’s policy. Appropriate supporting documentation could include semi-annual certifications for employees working solely on a single cost objective or personal activity reports or timesheets with sufficient detail when an employee works on multiple activities.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for the Procurement Standards in 2 CFR §§ 200.318 - 200.327. The Procurement Standards require entities to have and use their own documented procurement procedures, consistent with applicable State and local laws and regulations and the standards of 2 CFR 200.318 - .327, for the acquisition of property or services required under a Federal award or subaward. A non-Federal entity must, in part:
1. Meet the general procurement standards in 2 CFR 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR 200.320(a)(1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history, or other information and documents it files accordingly (2 CFR 200.320(a)(1)(ii)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(a)(2)(i)).
4. For acquisitions exceeding the simplified acquisition threshold, the non-Federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(b)(1); the competitive proposals method under the conditions specified in 2 CFR 200.320(b)(2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of five circumstances are met, in accordance with 2 CFR 200.320(c).
Additionally, Service Center Policy 6325 - Procurement indicates procurement of all supplies, materials, equipment, and services paid for from Federal funds or Educational Service Center matching funds shall be made in accordance with all applicable Federal, State, and local statutes and/or regulations, the terms and conditions of the Federal grant, Governing Board policies, and administrative procedures.The Service Center did not follow the federal procurement requirements and policy 6325 relating to procurement resulting in the following errors:
• For six of six tested expenditures that were subject to procurement, the Service Center could not produce support that these expenditures complied with federal procurement requirements and Service Center policy. Five of these expenditures were below the micro-purchase threshold in which the Service Center should have documented and maintained support that the price was reasonable. The remaining expenditure was a small purchase in which the Service Center should have documented and maintained price or rate quotations from an adequate number of qualified sources.
Failure to maintain the appropriate procurement documentation could lead to future findings, reduced federal funding and the requirement to repay the Ohio Department of Education.
The Service Center should ensure appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types. Appropriate supporting documentation could include copies of internet searches or other documented research for micro-purchases and documentation for price or rate quotations from an adequate number of qualified sources for small purchases.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for the Procurement Standards in 2 CFR §§ 200.318 - 200.327. The Procurement Standards require entities to have and use their own documented procurement procedures, consistent with applicable State and local laws and regulations and the standards of 2 CFR 200.318 - .327, for the acquisition of property or services required under a Federal award or subaward. A non-Federal entity must, in part:
1. Meet the general procurement standards in 2 CFR 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR 200.320(a)(1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history, or other information and documents it files accordingly (2 CFR 200.320(a)(1)(ii)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(a)(2)(i)).
4. For acquisitions exceeding the simplified acquisition threshold, the non-Federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(b)(1); the competitive proposals method under the conditions specified in 2 CFR 200.320(b)(2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of five circumstances are met, in accordance with 2 CFR 200.320(c).
Additionally, Service Center Policy 6325 - Procurement indicates procurement of all supplies, materials, equipment, and services paid for from Federal funds or Educational Service Center matching funds shall be made in accordance with all applicable Federal, State, and local statutes and/or regulations, the terms and conditions of the Federal grant, Governing Board policies, and administrative procedures.The Service Center did not follow the federal procurement requirements and policy 6325 relating to procurement resulting in the following errors:
• For six of six tested expenditures that were subject to procurement, the Service Center could not produce support that these expenditures complied with federal procurement requirements and Service Center policy. Five of these expenditures were below the micro-purchase threshold in which the Service Center should have documented and maintained support that the price was reasonable. The remaining expenditure was a small purchase in which the Service Center should have documented and maintained price or rate quotations from an adequate number of qualified sources.
Failure to maintain the appropriate procurement documentation could lead to future findings, reduced federal funding and the requirement to repay the Ohio Department of Education.
The Service Center should ensure appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types. Appropriate supporting documentation could include copies of internet searches or other documented research for micro-purchases and documentation for price or rate quotations from an adequate number of qualified sources for small purchases.