Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U – COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER III) Department of Education, Passed-Through Colorado Department of Education Award Number – 4414/4431/9414; Award Year 2021 Criteria: According to 2 CFR Part 200.403 factors affecting allowability of costs – costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. In addition, according to 2 CFR Part 200.303, the non-Federal entity must 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. Condition: During our testing we noted the following: a. 3 out of the 25 payroll selections applied to the grant did not agree back to supporting payroll information. b. The indirect costs applied to the grant were not consistently applied between the quarters of the fiscal year due to variations in the indirect cost base used. Questioned Costs: a. $2,089. Questioned costs were determined by reviewing the payroll registers for the three impacted selections. b. None. The District under applied the amount of indirect costs allowable to the grant. Context: a. We tested 25 payroll, 25 nonpayroll and 25 fringe benefit transactions applied to the grant for the year ended June 30, 2024. The tested population covered expenditures of $7.1 million and the total population of expenditures were approximately $24.4 million. A non-statistical sampling methodology was used to select the sample. b. We tested the four quarters indirect costs calculations which were applied to the above grant award numbers for the year ended June 30, 2024. The tested population covered expenditures of $3.0 million and the total population of expenditures were approximately $3.1 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Cause: The District continued to experience turnover within the positions overseeing grants during fiscal year 2024. There were not detailed reviews over the calculations and supporting documentation used to determine the expenditure amount to be applied to the grant. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the District strengthen the internal controls surrounding review of all expenditures applied against federal grants including the supporting detail or calculations used to determine the expenditure amount to help ensure it recalculates and is consistent with District polices and procedures. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.
Assistance Listing Number, Federal Agency, and Program Name - 93.323, U.S. Department of Health and Human Services, COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Award Identification Number and Year - 2024 Pass through Entity - Wayne County Regional Educational Service Agency Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.300(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 align with the 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). Per 2 CFR 200.403(g), costs must be adequately documented. Condition - The School District's controls did not prevent, or detect and correct in a timely manner, costs charged to the grant in excess of the related invoices. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below. Context - In a sample of 13 non payroll related transactions, we identified 3 transactions where the costs charged to the grant exceeded the related invoices. The School District used a manual allocation process through a manual journal entry to charge expenses to the grant that resulted in the grant being charged $48,447 in excess of the supporting invoices. As of June 30, 2024, the School District had not yet requested reimbursement for the excess costs charged; the request was made and payment was received subsequent to year end. Upon identification of the error, the School District posted a manual journal entry to remove the duplicate costs of $48,447 from the grant fund and reduced the SEFA by this amount for the year ended June 30, 2024. The School District followed the guidance of the pass through entity provided subsequent to year end. Cause and Effect - Controls in place did not prevent, or detect and correct in a timely manner, an instance of noncompliance. The controls in place to verify that the manual adjusting journal entry was complete and accurate were not effective. As a result, the initial SEFA provided to the auditors was overstated by $48,447. The SEFA for the year ended June 30, 2024 was corrected. Recommendation - We recommend that the School District review its processes and controls to ensure the preparation and review of journal entries to charge costs to grant funds include a review for duplicate expenses. Views of Responsible Officials and Corrective Action Plan - The Grant Accounting team will develop a standard operating procedure on review and approval of journal entries. The Grant Account Team will provide training to Grant Compliance staff members on the defined process. Grant Compliance Senior Director and Assistant Director will be responsible for ensuring journal requests are submitted following the outlined operating procedure. Grant Accounting staff members will review submitted materials to ensure no invoice is overcharged and then process journal request.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $730.43 Context: During the testing of payroll disbursements charged to the Education Stabilization Fund grant awards during the audit period, the following exceptions were noted: For 16 payroll disbursements, in a sample of 40, management was unable to provide an approved employee contract or hourly rate ordinance to support the selected employees' bi-weekly pay rate. For one transaction selection, an employee received a $730.43 one-time payment for a Teacher Appreciation Grant (TAG) funded by the 84.425U award. The Teacher Appreciation Grant has its own fund and is a state/local grant received to reward high-performing, eligible certified staff. The selected employee is a non-certified employee and did not qualify for a TAG award. There was no documentation provided to support work performed under this award to support allowability of the cost incurred. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District maintain supporting documentation for vendor and payroll disbursements to support costs charged to the federal grant awards. For payroll disbursements charged to Federal awards, management should maintain time records to support payroll costs allocated to Education Stabilization Grant funds to verify they are allowable and supported by documentation for work performed under the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number 2024-004: Costs Incurred Outside Period of Performance (Significant Deficiency in Internal Control over compliance and Instance of Noncompliance – Period of Performance) FALN Number 16.575; Federal Agency/Pass-through Entity – Program Name U.S. Department of Justice, Office of Victims of Crime – Crime Victim Assistance; Award Number 94-3302014; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.403(h) stated that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Condition/Context: As a result of our audit procedures, we noted 1 timesheet tested in which the costs incurred were charged outside of the program’s performance period. The timesheet had payroll costs incurred during the pay period of 12/24/2023 – 1/6/2024; however, the contract had a performance period of 1/1/2024 – 12/31/2024. Repeat Finding from Prior Year(s): Yes, Finding Number 2023-007 Cause and Effect: The Health System did not have proper controls in place to ensure only costs incurred in the period of performance were charged to the program, which resulted in costs outside of period of performance being charged to the program. Questioned Cost: None Recommendation: We recommend management review policies and procedures of the program to ensure the costs incurred are appropriately charged based on the contracts’ performance periods. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System has finalized the standard work procedure titled, Request for Funds/Reimbursement Claims (2-201’s), to ensure costs are appropriately charged based on the contract’s performance periods. Review of cost activity will occur in fiscal year 2025 to ensure policy is followed.
Criteria: Allowable Costs/Activites Allowed. The District is required to report allowable costs/activities allowed based on the grant, the grant budget and for the period of the grant. In general, grantees are not allowed to begin an activity or obligate or expend funds that will be charged to a state or federal grant until a substantially approvable initial application (see 34 CFR 76.708) has been received at ISBE. At a minimum, a “substantially approvable application” is a complete grant application and supporting budget detail with assurances. Grantees that submit a state or federal initial application prior to the program begin date (usually July 1) will be granted an appropriate project begin date for the following fiscal year unless state appropriation authority has not been approved. Grantees that submit a state or federal initial application after July 1 will be assigned a project begin date no earlier than when the initial application was received at ISBE or the program begin date (whichever is later). Condition: It was noted that the Title I grant application was submitted late, establishing a grant start date of 12/19/23. Due to the late start date, any expenditures that were obligated or services that were provided prior to the submittal date were not grant allowable costs. The expenditure reports that were submitted and subsequently reimbursed included costs from 7/1/23 - 12/18/23, which occured prior to the grant start date. Per 2 CFR 200.403(h) and guidelines established above, costs must be incurred during the approved budget period. Questioned Costs: There are $114,912 questioned costs associated with this grant. Context: The Title I grant application was submitted late, establishing a grant start date of 12/19/23. The expenditure report submitted on 3/8/24 for expenditures through that date, included salaries, benefits, purchased services, and supplies that occurred before the grant start date of 12/19/23. There are seven employees who are paid through the grant, and approximately 7 paychecks and benefits from July through the first December paycheck, totaling $99,364.87, were allocated and claimed in the 3/8/24 expenditure report under Instruction Salaries. There were two expenditures claimed in Instruction Supplies in the 3/8/24 expenditure report that were purchased in August 2023, totaling $497.09. There was one expenditure claimed in Other Support Services Supplies in the 3/8/24 expenditure report that was purchased in August 2023, totaling $1,512.50. There were 8 expenditures claimed in Assessment & Testing Purchased Services in the 3/31/24 expenditure report that were all purchased in July 2023, totaling $13,537.50. This sum of these expenditures claimed represent a total questioned costs of $114,911.96. Effect: The District mistakenly claimed $114,912 of unallowable expenses. There is an increased risk that these funds will be subject to repayment as they were incorrectly submitted for reimbursement. Cause: This was an oversight by management personnel in the District when submitting the first expenditure report for the grant. The District mistakenly included expenses occuring before the application start-date. Recommendation: The District should take steps to submit grant applications in a timely manner to ensure that they are able to claim all expenses as budgeted. The District should ensure that expenditure reports filed in grants with begin dates occuring after the start of the fiscal year does not include expenses occuring before the begin date, including reconciling general ledger records against the expenditure reports prior to submission. Management's Response: The District will take steps to submit grant applications in a timely manner. The District will take all necessary steps to reconcile the general ledger to the expenditure reports to ensure ineligible costs are not included on the expenditure report.
Criteria: Allowable Costs/Activites Allowed. The District is required to report allowable costs/activities allowed based on the grant, the grant budget and for the period of the grant. In general, grantees are not allowed to begin an activity or obligate or expend funds that will be charged to a state or federal grant until a substantially approvable initial application (see 34 CFR 76.708) has been received at ISBE. At a minimum, a “substantially approvable application” is a complete grant application and supporting budget detail with assurances. Grantees that submit a state or federal initial application prior to the program begin date (usually July 1) will be granted an appropriate project begin date for the following fiscal year unless state appropriation authority has not been approved. Grantees that submit a state or federal initial application after July 1 will be assigned a project begin date no earlier than when the initial application was received at ISBE or the program begin date (whichever is later). Condition: It was noted that the IDEA Preschool Flowthrough grant application was submitted late, establishing a grant start date of 12/19/23. Due to the late start date, any expenditures that were obligated or services that were provided prior to the submittal date were not grant allowable costs. The expenditure reports that were submitted and subsequently reimbursed included costs from 7/1/23 - 12/18/23, which occured prior to the grant start date. Per 2 CFR 200.403(h) and guidelines established above, costs must be incurred during the approved budget period. Questioned Costs: There are $4,646 questioned costs associated with this grant. Context: The IDEA Preschool Flowthrough grant application was submitted late, establishing a grant start date of 12/19/23. The expenditure report submitted 12/31/23 for expenditures through that date, included purchased services that occurred before the grant start date of 12/19/23. There were 2 expenditures claimed in Payments to Other Governmental Unit Purchased Services in the 12/19/23 expenditure report that were all purchased in September and November 2023, totaling $4,646, which represent the total questioned costs of for the grant years. Effect: The District mistakenly claimed $4,646 of unallowable expenses. There is an increased risk that these funds will be subject to repayment as they were incorrectly submitted for reimbursement. Cause: This was an oversight by management personnel in the District when submitting the first expenditure report for the grant. The District mistakenly included expenses occuring before the application start-date. Recommendation: The District should take steps to submit grant applications in a timely manner to ensure that they are able to claim all expenses as budgeted. The District should ensure that expenditure reports filed in grants with begin dates occuring after the start of the fiscal year does not include expenses occuring before the begin date, including reconciling general ledger records against the expenditure reports prior to submission. Management's Response: The District will take steps to submit grant applications in a timely manner. The District will take all necessary steps to reconcile the general ledger to the expenditure reports to ensure ineligible costs are not included on the expenditure report.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
2024–003 ALLOWABILITY‐PAYROLL Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Housing and Urban Development Community Development Block Grants/Entitlement Grants 14.218 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 200.430(g)(1) states, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally‐assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and (vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non‐Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR 200.403 indicates that costs must “be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity” and must “be adequately documented”. Condition: For 6 of the 17 payroll transactions selected for testing the individual’s hourly rate of pay charged to the federal program was not consistent with actual pay rates. Documentation supporting the difference in rate paid and rate reimbursed from the federal program was not available. Questioned Costs: $69 Context: Total federal expenditures for the Community Development Block Grant program were $3,436,560. The 6 payroll transactions represent $8,906 of the total payroll transactions tested of $24,915 for the program. Total payroll charged to the grant was $292,826. Cause: The City does not have adequate internal controls and policies and procedures in place to ensure that the payroll amounts reimbursed from the federal funds correspond to the payroll rates in the underlying payroll accounting records. Effect: The City is not be in compliance with federal statues, regulations, and terms of the conditions of the federal award. Expenditures were paid that are not allowable. The Authority may not identify noncompliance with federal statues, regulations, and terms of the conditions of the federal award including allowability. Recommendation: We recommend that City enhance internal controls to ensure that expenditures charged to the federal awards are properly reviewed and supported. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
2024–003 ALLOWABILITY‐PAYROLL Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Housing and Urban Development Community Development Block Grants/Entitlement Grants 14.218 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 200.430(g)(1) states, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally‐assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and (vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non‐Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR 200.403 indicates that costs must “be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity” and must “be adequately documented”. Condition: For 6 of the 17 payroll transactions selected for testing the individual’s hourly rate of pay charged to the federal program was not consistent with actual pay rates. Documentation supporting the difference in rate paid and rate reimbursed from the federal program was not available. Questioned Costs: $69 Context: Total federal expenditures for the Community Development Block Grant program were $3,436,560. The 6 payroll transactions represent $8,906 of the total payroll transactions tested of $24,915 for the program. Total payroll charged to the grant was $292,826. Cause: The City does not have adequate internal controls and policies and procedures in place to ensure that the payroll amounts reimbursed from the federal funds correspond to the payroll rates in the underlying payroll accounting records. Effect: The City is not be in compliance with federal statues, regulations, and terms of the conditions of the federal award. Expenditures were paid that are not allowable. The Authority may not identify noncompliance with federal statues, regulations, and terms of the conditions of the federal award including allowability. Recommendation: We recommend that City enhance internal controls to ensure that expenditures charged to the federal awards are properly reviewed and supported. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. The Uniform Guidance requires that non-federal entity must maintain records sufficient to detail the history of procurement and adherence to related compliance requirements. Records should include, but are not necessarily limited to, the following rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.318(i) Noncompetitive procurement can only be awarded if one or more of the following circumstances apply 2 CFR 200.320(c): The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. adequately document costs in accordance with 2 CFR 200.403(g). The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. 2 CFR 200.324(a). Per PDE and Pennsylvania Bulletin, the Entity must perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During our audits and PDE’s monitoring review completed in fiscal year 2023-2024, the ESSER Monitoring Team and we noted the following Procurement Findings: The School District was unable to provide purchase orders for several services purchased with Federal funds. The School District did not document its rationale for noncompetitive procurement. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Procurement files for 2 vendors, which exceed $10,000 but not $22,500 for goods and $10,000 but not $250,000 for services, did not have the accompanying three price or rate quotations. The School District did not conduct a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold of $250,000. Vendor contracts did not contain the necessary contract provisions The ESSER Monitoring Team was unable to obtain and review sufficient documentation to verify that the procurement was competitively performed for 1 vendor, such as proof of advertisement, request for proposal, bid evaluation, and award letter for procurement of the following vendor Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year. Cause: Non-compliance with Uniform Guidance Procurement requirements. Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance. Questioned Cost: None Identification of Repeat Finding: Yes Recommendation: The District must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now.
2024 - 011 Allowable Activities and Costs/Cost Principles - Payroll Federal Agency: U.S. Department of Justice Federal Program Name: Public Safety Partnership and Community Policing Grants Assistance Listing Number: 16. 710 Federal Award Identification Number and Year: 2020ULWX0001 - 2020 Award Period: 7/1/2020 - 6/30/2024 Type of Finding • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the recipient and subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to §200.403 Factors affecting allowability of costs of 2 CFR Part 200, costs must conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. The FY 2020 COPS Hiring Program (CHP) award provides funding to law enforcement agencies to hire and/or rehire career law enforcement officers. Specific to the City, CHP funding is for forty new hires. According to the award, the City may only be reimbursed for the approved cost categories that are documented within the Financial Clearance Memorandum (FC:M). Condition: During our testing, we noted the City paid incentive pay with CHP funding. Also, we noted the City paid salaries and fringe benefits for four officers not listed in the Date of Hire - COPS Officer List with CHP funding. Questioned costs: $16,882.17 Context: During our testing, it was noted that the City paid incentive pay of $3,000.00 for the pay period end 12/01/2023. The FCM does not have a cost category for incentive pay. Also, it was noted that the City paid salaries and fringe benefits of $13,882.17 for four officers not listed in the Date of Hire - COPS Officer List provided to the federal agency. Cause: The City charged the incentive pay to the grant by mistake. The City transferred the four officers to the grant during its initial years. The City moved the original forty officers to the grant and transferred any officers off the grant back to their positions funded by the general fund. These officers should have been moved out. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential pay back of federal funds. Recommendation: We recommend the City review costs charged to the grant to ensure the FCM has a cost category for the costs. We recommend the City review the officers charged to the grant to ensure they are listed in the he Date of Hire - COPS Officer List provided to the federal agency. For any questioned costs, we recommend the City work with the federal agency for resolution. Management Response: The City concurs with the finding. Albuquerque Police Department (APD) Grant Administrator will meet with the City Grant Administrator to review and prepare the necessary payroll corrections, ensuring that all payroll charges allocated to the grant are accurate. The APD Grant Administrator will be responsible for submitting correcting payroll reclassifications to the City's Grants Management Section for review, entry and approval no later than January 31, 2025. APD will work directly with the City's Grants Management Section to establish new reconciliation, reclassification and validation processes to ensure that only eligible officers and pay types are charged to the grant. Timeline and Responsible Position: January 2025 - APD Grant Administrator
FINDING 2024-003 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, there was not an approved salary ordinance for noncertified staff for fiscal year 2023-2024. Of the nine paychecks selected for testing, three did not have hourly rates approved by the governing body. It was further determined that all noncertified staff employees did not have the hourly rates approved by the governing body for 2023-2024. Therefore, we were not able to determine if the amounts paid to these employees were appropriate. The lack of internal controls and noncompliance was limited to payroll disbursements of noncertified employees during 2024. 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: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(g)(1) states in part: "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (ix) Because practices vary as to the activity constituting a full workload (for example, the Institutional Base Salary (IBS) for IHEs), records may reflect categories of activities expressed as a percentage distribution of total activities. (x) It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. Therefore, a precise assessment of factors contributing to costs is not required when IHEs record salaries and wages charged to Federal awards . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs The total of known questioned costs was $219,188. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure compliance and comply with the grant agreement and Allowable Costs/Cost Principles compliance requirement. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. 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: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, there was not an approved salary ordinance for noncertified staff for fiscal year 2023-2024. Of the nine paychecks selected for testing, three did not have hourly rates approved by the governing body. It was further determined that all noncertified staff employees did not have the hourly rates approved by the governing body for 2023-2024. Therefore, we were not able to determine if the amounts paid to these employees were appropriate. The lack of internal controls and noncompliance was limited to payroll disbursements of noncertified employees during 2024. 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: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(g)(1) states in part: "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (ix) Because practices vary as to the activity constituting a full workload (for example, the Institutional Base Salary (IBS) for IHEs), records may reflect categories of activities expressed as a percentage distribution of total activities. (x) It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. Therefore, a precise assessment of factors contributing to costs is not required when IHEs record salaries and wages charged to Federal awards . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs The total of known questioned costs was $219,188. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure compliance and comply with the grant agreement and Allowable Costs/Cost Principles compliance requirement. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Information on Federal Program:United States Department of Health and Human Services Assistance Listing Number: 93.667Assistance Listing Name: Social Services Block Grant Pass-Through Awards under the Uniform Guidance Requirements:Pass-Through Entity Award Number Award Period Ohio Department of Job and Family Services HS157289 January 1, 2023 - December 31, 2023, and January 1, 2024 - December 31, 2024Criteria: CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented and there must be sufficient documentation.Condition: During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Organization’s Title XX federal program. The Organization did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. The Organization inadvertently overallocated the time allocation for the program; however, total costs incurred by the Organization after exclusion of the overallocation were not in excess of the amounts funded by the program. Cause: The Organization did not have specific policies and procedures in place as to how monthly personnel costs across federal programs are to be aggregated and charged to federal programs. Effect or Potential Effect: An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards could lead to noncompliance with law and regulations and possible loss of funding for the related program. Repeat Finding: This is a repeat finding. Questioned Costs: None. Context: The Organization collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure did not exist at the time to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing. Recommendation: We recommend that the Organization continues their new policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation, thus demonstrating the level of effort under the uniform guidance. We further recommend that management continue to review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and the recommendation.
Information on Federal Program:United States Department of Health and Human Services Assistance Listing Number: 93.667Assistance Listing Name: Social Services Block Grant Pass-Through Awards under the Uniform Guidance Requirements:Pass-Through Entity Award Number Award Period Ohio Department of Job and Family Services HS157289 January 1, 2023 - December 31, 2023, and January 1, 2024 - December 31, 2024Criteria: CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented and there must be sufficient documentation.Condition: During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Organization’s Title XX federal program. The Organization did not adequately document hours worked per employee per submission, and accordingly, time and effort were not properly supported on a monthly basis. The Organization inadvertently overallocated the time allocation for the program; however, total costs incurred by the Organization after exclusion of the overallocation were not in excess of the amounts funded by the program. Cause: The Organization did not have specific policies and procedures in place as to how monthly personnel costs across federal programs are to be aggregated and charged to federal programs. Effect or Potential Effect: An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards could lead to noncompliance with law and regulations and possible loss of funding for the related program. Repeat Finding: This is a repeat finding. Questioned Costs: None. Context: The Organization collects timecards for all employees for submission and approval prior to biweekly payroll. However, a policy or procedure did not exist at the time to ensure that the actual hours incurred (time and effort) billed to the federal agencies on a monthly basis is fully supported at the time of invoicing. Recommendation: We recommend that the Organization continues their new policy and procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepare a monthly analysis to support the actual amounts allocated across all programs and invoiced to the awarding agencies, reconciled to payroll reports, which then will allow to evidence that all hours submitted for reimbursement are supported with timecards or appropriate allocation, thus demonstrating the level of effort under the uniform guidance. We further recommend that management continue to review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and the recommendation.
Assistance Listing Number(s): 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families (TANF) Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Boys & Girls Clubs of Fox Valley Award Period: July 1, 2023 through June 30, 2024 Criteria: Per 2 CFR 200.403(c) costs charged to the Federal award must be consistent with policies and procedures that apply Uniformly to both federally financed and other activities of the subrecipient. Condition: An individual was charged to the Federal awards as an employee when the individual was contracted as an independent contractor. The award budgets did not include contractor services. Cause: The individual was an employee up until October 9, 2023 when the independent contractor agreement was entered. No controls are in place to identify changes that costs are no longer recorded consistently with policies and procedures. Effect or Potential Effect: Independent contractor costs charged are questioned and may be disallowed and repayment made. Recommendation: Independent contractors are to be recorded to a contractor general ledger account per policies and procedures. A review of personnel costs to identify changes in personnel, ensure transactions are recorded per policies and procedures, and that award budgets are amended if necessary. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procedures.
Assistance Listing Number(s): 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families (TANF) Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Boys & Girls Clubs of Fox Valley Award Period: July 1, 2023 through June 30, 2024 Criteria: Per 2 CFR 200.403(c) costs charged to the Federal award must be consistent with policies and procedures that apply Uniformly to both federally financed and other activities of the subrecipient. Condition: An individual was charged to the Federal awards as an employee when the individual was contracted as an independent contractor. The award budgets did not include contractor services. Cause: The individual was an employee up until October 9, 2023 when the independent contractor agreement was entered. No controls are in place to identify changes that costs are no longer recorded consistently with policies and procedures. Effect or Potential Effect: Independent contractor costs charged are questioned and may be disallowed and repayment made. Recommendation: Independent contractors are to be recorded to a contractor general ledger account per policies and procedures. A review of personnel costs to identify changes in personnel, ensure transactions are recorded per policies and procedures, and that award budgets are amended if necessary. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing procedures.
FINDING 2024-004 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): 22611-048-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation is a member of the Ripley-Ohio-Dearborn Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education programs and spent the federal money for earmarked expenditures on behalf of four of the six member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and the member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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 Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The nonpublic school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the nonpublic schools. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 22611-048-PN01 grant award in 2022-2023. INDIANA STATE BOARD OF ACCOUNTS 20 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure time worked by certified staff for nonpublic schools was properly identified. Internal controls in place did not identify that an improper method was used to identify expenditures for nonpublic students with disabilities. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure that the proportionate share required to be expended for nonpublic students was met. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 21 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure nonpublic proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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