Audit 402103

2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430(g)(1)(i) which 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. 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. Due to insufficient controls over records management, the District did not maintain semi-annual certifications, or other time and effort documentation for 20 out of 25 transactions tested (80%). These errors could result in improper spending and federal questioned costs, which could result in a loss of funding. To effectively control the Nutrition Cluster payroll cycle and to maintain accountability over program expenditures, the District should review its policy and ensure employees complete the necessary time and effort documentation, such as semi-annual certifications, for employees who work solely on a single federal award or cost objective.