Audit 401184

2025-003 Time & Effort and Semi-Annual Certifications Type of Finding: Significant Deficiency in Internal Control Over Compliance New or Repeat Finding: Repeat; see prior year finding #2024-007. Federal Program: Special Education Cluster (ALNs 84.027, 84.173); Head Start Cluster (ALN 93.600) Federal Agency: U.S. Department of Education (Special Education Cluster); U.S. Department of Health and Human Services (Head Start Cluster) Pass-through Entity(ies): Special Education Cluster - Texas Education Agency (246600010849086600, 256600010849086600, 246610010849086610, 256610010849086610, 66002406); Head Start Cluster - N/A Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The District was not able to provide in a timely manner the required time & effort and semiannual certifications for employees who worked on the Special Education and Head Start clusters. These certifications, which confirm that the employee worked 100% on the program for the period covered, were not completed timely, but were ultimately provided prior to conclusion of the audit. Cause: The District was in the process of implementing the corrective action plan from the previous fiscal year's audit, which consisted of procedures to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Effect or Potential Effect: Without semi-annual certifications, the District would lack the required documentation to fully support salary costs charged to the grant. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as the District ultimately provided audit evidence to support the time worked on the grant. In addition, the personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by their appropriate grant-funded position. Context: The District was unable to provide timely the required semi-annual certifications for 2 out of 5 employees selected in our sample for testing for the Special Education Cluster. The District was unable to provide timely the required semi-annual certifications for 39 out of 39 employees selected in our sample for testing for the Special Education Cluster. Ultimately, semi-annual certifications were provided for all employees in our sample that remained charged to their respective grant for fiscal year 2025. Recommendation: We recommend that the District continue to implement procedures to ensure that semi-annual certifications are prepared, signed, and retained for all employees working solely on federal programs. The District should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2026 to ensure semi-annual certifications are completed appropriately.