Management recognizes that there was inadequate documentation from multiple districts to support salary and benefit costs within the Title I Grants to Local Educational Agencies program. Also, Centennial BOCES recognizes, as the fiscal agent, that it is the entity responsible for compliance with the...
Management recognizes that there was inadequate documentation from multiple districts to support salary and benefit costs within the Title I Grants to Local Educational Agencies program. Also, Centennial BOCES recognizes, as the fiscal agent, that it is the entity responsible for compliance with the rules and regulations of the program, including for those activities taking place at each district. As a result, the Chief Financial Officer will work with the Grants Accountant that manages this program and the distribution of funds to these districts. Ultimately, corrective action will have several aspects: general training and education, targeted training and education for those districts needing more support, and follow-up with districts to ensure accountability and integrity with the rules and regulations surrounding finding # 2024- 001 cited in this single audit. The first level of corrective action will be sending resources by email to each district in our ESSA consortium. These resources will focus around the requirements of time and effort, in order to support salary and benefit costs charged to federal funds. These resources will contain informational content around time and effort requirements and citations to the Cost Principles, as well as examples and scenarios to guide districts through the proper process of documenting these costs. These emails will be to both the fiscal and program representatives at each district, and will take place in Fall 2025. Targeted support will be provided to those districts cited by the auditors as having insufficient time and effort documentation to support the salary and benefits charged to the Title I Grants to Local Educational Agencies program. In addition to the previously named elements, this will include scheduling meetings with the district fiscal representative, district program representative, CBOCES Chief Financial Officer, and CBOCES Grants Accountant. These meetings will take place either through a phone call, Zoom, or in person. In these meetings we will go over why the district documentation was deemed insufficient, and then have a conversation around the resources provided and how we can help bring the district into compliance and sustain that compliance going forward. These meetings will be scheduled during Fall 2025.As the final element of this corrective plan, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY26. For districts with adequate documentation, we will ask for time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. For districts with inadequate documentation, we will ask for a sample of two months of time and effort documentation during the fiscal year to monitor progress. If sufficient, no further action will be required of the district. If insufficient, CBOCES will contact the district and work to remediate any inadequacies or questions. These districts will also be required to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Recognizing the timing of this single audit report, Centennial BOCES will need to address the current time and effort documentation at districts for FY25. Before training activities begin in Fall 2025, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY25. If found to be insufficient, we will work with applicable districts to correct their documentation and prepare for training activities. This work will be tailored to the specific needs of each district. For future fiscal years beyond FY26, CBOCES will work to maintain compliance by asking each district to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Also, new fiscal and program representatives at districts will be provided with the training and education documents named in the second paragraph of this action plan.