Finding 2022-003: Inadequate Support for Salaries and Wages-Time Certifications not maintained (5000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II...
Finding 2022-003: Inadequate Support for Salaries and Wages-Time Certifications not maintained (5000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425, C, D, U), Title I (Assistance Listing 84.010) Criteria: 2 CFR 200.430 requires that an LEA must maintain time and effort distribution records that support the distribution of the employee?s salary or wages among specific activities or cost objectives. 2 CFR, section 225, appendix B, Section 8(h) states in part: Support of salaries and wages- These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with the generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employee worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: Be prepared at least semi-annually. Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective?. Personnel Activity Report Except as provided in ?Substitute Systems for Time Accounting,? employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee?s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee?s work activities. The safest approach is to provide more documentation rather than less. Finding: The District provided approved time sheets for only 3 employees out of 20 selected that were paid from ESSER funding. The District provided 9 of 10-time accounting records that included PARS for Title I. Cause: The District does not have adequate controls in place to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: The District did not provide time certification records for 17 of the 20 employees selected for review, who were paid with Education Stabilization Funds. As a result, the amount of $736,116.27 is in question. The District did not provide time certification records for 1 of 8 employees selected for review, who was paid with Title I funds, as a result, the amount of $ 91,794, is in question. Recommendation: We recommend the District comply with Title 2, CFR 200.303, and CSAM Procedure 905 which require that employee time certification forms be maintained for employees who charge time to federal programs. Action: Management will ensure that the District does have adequate controls in place and comply with Federal rules and guidelines. Completion Date: Effective immediately. Contact: Zach Klemish, Director of Fiscal Services, Adelanto Elementary School District, (760) 246-8691