Finding: During the audit, it was identified that severance pay for a former employee was charged to the Title I, Part A program. This expenditure is unallowable under 2 CFR §200.431(i), which permits severance payments only when reasonable, necessary, and consistent with written policy and prior ap...
Finding: During the audit, it was identified that severance pay for a former employee was charged to the Title I, Part A program. This expenditure is unallowable under 2 CFR §200.431(i), which permits severance payments only when reasonable, necessary, and consistent with written policy and prior approval requirements. Root Cause: The unallowable cost occurred due to a breakdown in internal controls among Payroll, HR, Finance, and Federal Programs. The Payroll Department processed the severance payment without verifying the funding source’s allowability, and there was no secondary review by Finance, HR, or Federal Programs to identify and reclassify the cost prior to posting. This lack of coordinated oversight led to the unallowable charge to Title I, Part A. Corrective Action Steps 1. Reimbursement of Unallowable Costs o The organization will reimburse the Title I, Part A program from local funds for the total amount of severance pay charged in error. o Documentation of the reimbursement (journal entry and general ledger report) will be retained in the audit file. 2. Policy and Procedure Revision o The organization will revise its federal programs expenditure review, payroll, finance, and HR procedures to ensure all personnel-related transactions - including severance, stipends, and separation payments - are reviewed for federal allowability before processing. o Payroll must verify the allowability of the funding source with the Federal Programs Office prior to processing any non-routine payments. o HR will confirm appropriate coding and funding source alignment during separation processing. o A pre-approval checklist will be implemented for all employee separation and severance actions. 3. Staff Training o Payroll, HR, Finance, and Federal Programs staff will receive targeted training on EDGAR Subpart E (Cost Principles) and allowability standards under Title I, Part A. o Training will emphasize cross-departmental accountability and the importance of accurate funding verification. o Attendance and training documentation will be retained for audit records. 4. Ongoing Monitoring and Quality Control o The Federal Programs Director, Payroll Director, Finance Director, and HR Director will jointly conduct quarterly monitoring reviews of payroll and personnel transactions charged to federal grants to verify allowability and compliance. o The reviews will include reconciliation of HR separation records, Payroll disbursements, and Federal Programs expenditure reports. o The first joint monitoring review will occur within 60 days of CAP approval. Responsible Parties: • Chief Financial Officer (CFO): Oversees reimbursement, approves policy updates, and ensures CAP implementation. • Finance Director: Verifies accurate cost classification, supports monitoring reviews, and ensures compliance with fiscal controls. • Federal Programs Director: Ensures compliance with federal allowability requirements and leads monitoring activities. • Payroll Supervisor: Confirms allowability of all payroll transactions before disbursement. • HR Director: Ensures accurate coding, separation documentation, and funding alignment for personnel actions. Completion Timeline: • Reimbursement: Within 30 days of CAP submission. • Policy and Procedure Revision: Within 45 days. • Training and Monitoring Implementation: Within 60 days. Verification of Implementation: Evidence of completion - including reimbursement documentation, revised policies and procedures, training records, and the first monitoring report - will be submitted to the auditor and TEA as required.