2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-005 U.S. Department of Education, Assistance Listing #84.010, Title 1A Disadvantage for the period July 1, 2023 through June 30, 2024
Criteria: Per 2 CFR 200.402, reimbursable costs for a Federal award are the sum of the allowable direct and allocable indirect costs minus any applicable credits.
Condition: The School Department requests grant reimbursements on a periodic basis utilizing expense detail recorded in the accounting system’s general ledger. Throughout the year, adjustments may be made to the general ledger to correct errors and misclassifications or to reverse prior period accruals. During 2024, the School Department requested reimbursement for fiscal year 2023 expenses utilizing the expenses recorded on the general ledger. However, several adjustments had been made to reduce grant expenditures that were not captured in the requests.
Cause: The School Department misinterpreted the expense detail for the grant by not taking into account negative adjustments to expenses.
Effect: Reimbursement requests exceeded net expenditures by $113,884, resulting in questioned costs for the program that should be refunded to the grantor agency.
Recommendation: We recommend grant requests be based on net expenditures that take into account all debit and credit activity during the period.
Questioned Costs: $113,884
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Twenty-three of forty-two disbursements tested (55%) for the Equitable Sharing Program did not have documented review and approval by a knowledgeable program staff person. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds. Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
Management’s Response/Corrective Action Plan: This program received significantly more distributions in 2024 than the City had received in the past. The funds initially were not considered to be federal since the source was private companies, but staff has since taken required grant agency training. The City is implementing workflow for purchasing and credit card transactions which will provide electronic approvals and the ability to attach receipts.
2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-007 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Out of forty payroll disbursements tested for the Federal Transit Cluster, thirteen timecards were missing documentation of supervisory approval and five timecards did not match the hours paid.
Cause: Lack of administrative personnel at the Bus Station resulted in a breakdown of established internal control procedures over payroll.
Effect: The errors caused improper payments for five of the forty paychecks tested. Actual overpayments of $436 were identified in our sample with an extrapolated overpayment of $11,533 across the population.
Recommendation: We recommend evaluating staffing workloads to ensure adequate supervision of the payroll function at the Bus Station.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-008 U.S. Department of Transportation, Assistance Listing #20.507 and #20.526, Federal Transit Cluster Formula Grants for the period July 1, 2023 through June 30, 2024
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Sixteen of sixty disbursements tested (27%) for the Federal Transit Cluster Formula Grant did not have documented review and approval by a knowledgeable program staff person. In addition, two of sixty disbursements totaling $68.73 tested for the program had no supporting documentation. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds.
Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
2024-005 U.S. Department of Education, Assistance Listing #84.010, Title 1A Disadvantage for the period July 1, 2023 through June 30, 2024
Criteria: Per 2 CFR 200.402, reimbursable costs for a Federal award are the sum of the allowable direct and allocable indirect costs minus any applicable credits.
Condition: The School Department requests grant reimbursements on a periodic basis utilizing expense detail recorded in the accounting system’s general ledger. Throughout the year, adjustments may be made to the general ledger to correct errors and misclassifications or to reverse prior period accruals. During 2024, the School Department requested reimbursement for fiscal year 2023 expenses utilizing the expenses recorded on the general ledger. However, several adjustments had been made to reduce grant expenditures that were not captured in the requests.
Cause: The School Department misinterpreted the expense detail for the grant by not taking into account negative adjustments to expenses.
Effect: Reimbursement requests exceeded net expenditures by $113,884, resulting in questioned costs for the program that should be refunded to the grantor agency.
Recommendation: We recommend grant requests be based on net expenditures that take into account all debit and credit activity during the period.
Questioned Costs: $113,884
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds
Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards.
Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis.
Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs.
Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked.
Questioned Costs: None
Criteria: Administrative requirements under the Uniform Guidance require grantees to develop internal controls and procedures sufficient to prevent noncompliance.
Condition: Twenty-three of forty-two disbursements tested (55%) for the Equitable Sharing Program did not have documented review and approval by a knowledgeable program staff person. All exceptions noted were related to credit card purchases.
Cause: Control policies are not consistent across the organization and do not require a knowledgeable program person to document their review of credit card expenditures coded to Federal grants prior to entry into the accounting system.
Effect: Unallowable costs may be charged to grants which may lead to repayment of grant funds. Recommendation: We recommend reviewing policies and procedures regarding monthly credit card reconciliations to ensure that a knowledgeable program person is approving the coding of credit card purchases to grant funds prior to their entry into the accounting system.
Questioned Costs: None
Management’s Response/Corrective Action Plan: This program received significantly more distributions in 2024 than the City had received in the past. The funds initially were not considered to be federal since the source was private companies, but staff has since taken required grant agency training. The City is implementing workflow for purchasing and credit card transactions which will provide electronic approvals and the ability to attach receipts.