Audit 391584

Finding Number: 2025-004 Federal Program: Title I Federal Award Identification Number and Year: 2025 Assistance Listing Number (ALN): 84.010A Federal Awarding Agency: U.S. Department of Education Pass-through Entity: Ohio Department of Education and Workforce Compliance Requirements: Allowable Costs/Allowable Activities Repeat Finding: No Significant Deficiency/ Noncompliance – Time & Effort Criteria: 2 CFR § 3474.1 gives regulatory effect to the Office of Management Budget guidance in 2 CFR § 200 for the Department of Education. 2 CFR § 200 Subpart E which states, in part, costs must be adequately documented in order to be considered allowable. 2 CFR § 200.430(g)(1)(i) states, in part, 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 that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The Ohio Department of Education and Workforce’s Grants Manual states, in part, semi-annual certifications are allowed when an employee’s compensation is funded by only one federal grant and works solely on a single cost objective. An employee funded by a federal grant and the general fund would fall under this category. Finding Number: 2025-004 (Continued) Significant Deficiency/ Noncompliance – Time & Effort (Continued) Criteria (continued): The Ohio Department of Education and Workforce’s Grants Management Guidance 2014-002 states, in part, employees who meet [the criteria to use semi-annual certifications] are not required to maintain time and-effort records if their job description clearly shows the employee is assigned 100% to the program or single cost objective. Each employee must certify in writing, at least semi-annually, that he/she worked solely on the program or single cost objective for the period covered by the certification. The certification is signed by the employee or by the supervisor having first-hand knowledge. Charges to the grant must be supported by these semi-annual certifications. The semi-annual certification is executed after the work has been completed, and not before. Condition: We performed a test of controls and compliance over allowable costs/cost principles for payroll expenditures charged during fiscal year 2025. Semi-annual certifications were not completed for one semiannual period for two employees. Cause: Error when completing the semi-annual certifications. Effect: Although we did not identify any unallowable costs, the lack of controls over the time and effort documentation subjects the School District to an increased risk of unallowable costs being charged to the federal programs. Recommendation: We recommend the School District review the individuals paid out of the federal funds to ensure the amounts are allowable. After this review, the School District should ensure the proper time and effort documentation exists in accordance with the requirements above. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.