Audit 42532

FY End
2022-06-30
Total Expended
$4.36M
Findings
6
Programs
11
Organization: Bryan City School District (OH)
Year: 2022 Accepted: 2023-03-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
50363 2022-002 Significant Deficiency - B
50364 2022-002 Significant Deficiency - B
50365 2022-002 Significant Deficiency - B
626805 2022-002 Significant Deficiency - B
626806 2022-002 Significant Deficiency - B
626807 2022-002 Significant Deficiency - B

Contacts

Name Title Type
EFNJY25CGNV6 Kevin Schafer Auditee
4196336024 Jonathan A. Lawless, Cfe Auditor
No contacts on file

Notes to SEFA

Title: NOTE A BASIS OF PRESENTATION Accounting Policies: NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIESExpenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: NOTE C INDIRECT COST RATEThe District has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of Bryan City School District, Williams County, Ohio (the District) under programs of the federal government for the year ended June 30, 2022. The information on this Schedule is prepared in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the District, it is not intended to and does not present the financial position or changes in net position of the District.
Title: NOTE D SUBRECIPIENTS Accounting Policies: NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIESExpenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: NOTE C INDIRECT COST RATEThe District has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The District passes certain federal awards received from the Ohio Department of Education to other governments or not-for-profit agencies (subrecipients). As Note B describes, the District reports expenditures of Federal awards to subrecipients when paid in cash.As a subrecipient, the District has certain compliance responsibilities, such as monitoring its subrecipients to help assure they use these subawards as authorized by laws, regulations, and the provisions of contracts or grant agreements, and that subrecipients achieve the awards performance goals.
Title: NOTE E CHILD NUTRITION CLUSTER Accounting Policies: NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIESExpenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: NOTE C INDIRECT COST RATEThe District has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The District commingles cash receipts from the U.S. Department of Agriculture with similar State grants. When reporting expenditures on this Schedule, the District assumes it expends federal monies first.
Title: NOTE F FOOD DONATION PROGRAM Accounting Policies: NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIESExpenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: NOTE C INDIRECT COST RATEThe District has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The District reports commodities consumed on the Schedule at the entitlement value. The District allocated donated food commodities to the respective program that benefitted from the use of those donated food commodities.
Title: NOTE G TRANSFERS BETWEEN PROGRAM YEARS Accounting Policies: NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIESExpenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: NOTE C INDIRECT COST RATEThe District has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Federal regulations require schools to obligate certain federal awards by June 30. However, with ODEs consent, schools can transfer unobligated amounts to the subsequent fiscal years program. The District transferred the following amounts from 2022 to 20232 programs: [See table in reporting package.]

Finding Details

Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation