Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Number and Year (or Other Identifying Number): 22611-053-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters INDIANA STATE BOARD OF ACCOUNTS 21 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-005. Condition and Context The School Corporation is a member of the South La Porte County Special Education (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. Due to the timing of the Cooperative's corrective action, the nonpublic expenditures spent did not meet the earmarking requirements for grant award number 22611-053-PN01. From the beginning of the grant awards until March 2023, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through March 2023, as required. The lack of internal controls and noncompliance was isolated to 22611-053-PN01 grant award. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Through management inquiry, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in March 2023, most of the grant award had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Number and Year (or Other Identifying Number): 22611-053-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters INDIANA STATE BOARD OF ACCOUNTS 21 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-005. Condition and Context The School Corporation is a member of the South La Porte County Special Education (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. Due to the timing of the Cooperative's corrective action, the nonpublic expenditures spent did not meet the earmarking requirements for grant award number 22611-053-PN01. From the beginning of the grant awards until March 2023, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through March 2023, as required. The lack of internal controls and noncompliance was isolated to 22611-053-PN01 grant award. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Through management inquiry, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in March 2023, most of the grant award had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The non-public expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP prior to September 2022. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of the Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure the Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.403 requires that costs “be necessary and reasonable for the performance of the Federal award.” Costs should not consist of improper payments, including payments that were not eligible under the award document. Condition: The Town received a reimbursement for a cost from an award for “blighted property” that was not an eligible expense under the grant agreement. Cause: The Town’s controls related to allowable costs for individual grant agreements were not operating effectively. Effect or Potential Effect: Unallowable expenditures may have been paid with federal funds. Questioned Costs: $19,569 Context: Total federal expenditures for the Community Development Block Grants-State's Program and Non-Entitlement Grants in Hawaii were $1,450,668 for the fiscal year ended June 30, 2024. Identification of a Repeat Finding: This is not a repeat finding from the prior year. Recommendation: Officials should ensure that the control of personnel adequately reviewing award requirements before submitting for reimbursement of a particular cost is operating effectively. Furthermore, officials should consider a secondary review of reimbursement requests. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the issue.