Audit 382194

2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster: Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Criteria: Salaries and wages charged to Federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart I, 2 CFR §200.430, which requires records that accurately reflect the work performed and reasonably support the distribution of compensation among specific activities or cost objectives. Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s PARs were not signed by the employees. In addition, PARs for employees not charged 100% to a single grant were prepared retrospectively after year end rather than periodically throughout the year. Cause: Employee PAR forms should accurately reflect time and effort, as described in Subpart I, 2 CFR §200.430, to support salaries, and other forms of compensation charged to a federal program. During our audit, based on sample testing and inquiries, we noted the District’s procedures did not require the preparation and review of PARs, or equivalent documentation, on a periodic basis during the year. As a result, time and effort documentation was completed retrospectively after year end rather than contemporaneously with the work performed. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the Federal awards. Questioned Costs: Dollar amount undetermined as some PARs were not completed timely or signed by the employee. Context: For the Special Education Cluster, based on a sample of five (5) employees, we noted that three (3) of the five (5) PARs were not signed by the employee, and in two (2) instances we noted PARs were distributed only after year end, rather than periodically throughout the year for those employees who are not charged 100% to a grant. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should establish procedures to ensure that PARs, or equivalent time-and-effort documentation, are prepared periodically for employees working on multiple cost objectives and comply with the requirements of Subpart I, 2 CFR §200.430 of the Uniform Guidance. In addition, the District should ensure all PAR forms are properly completed, signed by the employee, and subject to timely supervisory review. Views of Responsible Officials of Auditee: The District acknowledges the finding and will enhance its procedures related to federal PARS to ensure that employee’s salary, or other forms of compensation charged to federal awards, are properly signed off by the employee. In addition, the District will implement procedures to ensure that PARs, or equivalent time-and-effort documentation, are prepared more than once throughout the year for employees who are not charged 100% to a single federal grant in compliance with Subpart I, 2 CFR §200.430.