Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal Program Information U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Energy, CFDA Number 81.042, Weatherization Assistance for Low-Income Persons; U.S. Department of Justice, CFDA Number 16.575, Crime Victim Assistance; U.S. Department of Veterans Affairs, CFDA Number 64.033, Supportive Services for Veteran Families and Corporation for National and Community Service, CFDA Number 94.011, Foster Grandparent/Senior Companion Cluster Criteria The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition For the year ended July 31, 2023, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2023, there is no formal documentation of this review process. Questioned Costs Not determinable. Context For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2023. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views Of Responsible Officials and Planned Corrective Actions For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until fiscal year 2025 given the timing of the fiscal year 2021 and 2022 audits and receipt of this finding.
Allowable Costs/Cost Principles - Time and Effort Reporting (Repeat Observation) Federal Program Information U.S. Department of Health and Human Services, CFDA Number 93.600, Head Start Program and Early Head Start Child Care Partnership/Babies Step Forward; U.S. Department of Health and Human Services, CFDA Number 93.569/93.558, 477 Cluster; U.S. Department of Health and Human Services, CFDA Number 93.568, Low-Income Energy Assistance; U.S. Department of Energy, CFDA Number 81.042, Weatherization Assistance for Low-Income Persons; U.S. Department of Justice, CFDA Number 16.575, Crime Victim Assistance; U.S. Department of Veterans Affairs, CFDA Number 64.033, Supportive Services for Veteran Families and Corporation for National and Community Service, CFDA Number 94.011, Foster Grandparent/Senior Companion Cluster Criteria The Code of Federal Regulations Section 200.430 (2 CFR 200.430) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Budget estimates determined prior to services being performed by personnel may be used for interim accounting processes, but the organization’s internal controls must include a process to review these charges after services have been performed to make any necessary adjustments to ensure that final amounts charged to federal awards are accurate, allowable and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards. Charges for salaries and wages must be supported by documentation that is incorporated into the official records of the organization. Condition For the year ended July 31, 2023, WestCOP and Affiliates used status change forms to document an estimation of the distribution of employees’ salaries and wages among specific programs. Management’s process is to complete a status change form for an employee upon hire and then modify the form when there is a significant change in an employee’s duties impacting the allocation of time and effort among programs. The accounting department uses the distribution documented in the status change form to determine how to charge an employee’s compensation to programs and federal awards. While management has communicated to the auditors that regular reviews of actual personnel time and effort were performed during the year ended July 31, 2023, there is no formal documentation of this review process. Questioned Costs Not determinable. Context For all major programs tested, management did not provide documentation of its review of actual personnel time and effort after employee services were provided, such as personnel time reports or any other documented analysis of how personnel actually spent their time versus the estimates. Personnel costs represent a significant component of the total cost charged to the three major programs for the year ended July 31, 2023. We were able to recalculate the charges based on the estimated distributions per employee status change forms. Several selected employees for each program also spend 100% of their time on the programs, so allocations are not applicable. Effect WestCOP and Affiliates were unable to demonstrate that personnel costs charged to the major federal award programs reflected actual time incurred on the programs that were properly supported in compliance with the time and effort reporting requirements described in 2 CFR 200.430. Cause Management does not have a formal, documented process to review actual personnel time and effort after employee services are performed to ensure that charges to federal awards based on estimates are accurate. Charges to federal awards are based on estimates documented in personnel status change forms prior to services being performed. While these forms may be updated periodically to reflect changes in estimates of personnel time and effort, the updates are not supported by any documented analysis of actual time and effort. Recommendation Management can continue using the estimates of the distribution of employees’ time per status change forms for interim accounting processes. However, we recommend that management formally document a process to periodically review the actual distribution of employee time and effort among federally-funded programs. Management can determine the frequency of this documentation, but we recommend that such review be formally documented at least monthly. Documentation could be in the form of personnel time and effort reports reflecting the distribution of actual time among programs prepared by employees and reviewed by direct supervisors. Alternatively, management personnel familiar with employees’ activities, such as direct supervisors, could prepare periodic analyses of the distribution of employee time and effort to support allocations and charges of salaries and wages to federal awards. Views Of Responsible Officials and Planned Corrective Actions For employees who are paid in full or in part with federal and other funds, management will increase the frequency of the time and effort reporting to quarterly intervals. Specifically, employees will document their time and effort based on funding sources for each payroll period; and at the end each quarter, management will review and compare the actual time and effort percentages with the current ADP Labor Distribution Report for reasonableness. The Management review report will be used as a basis to effect changes to the labor distribution report using the employee status change forms. The time and effort documentation will be available for audit. The implementation of the Corrective Action Plan did not commence until fiscal year 2025 given the timing of the fiscal year 2021 and 2022 audits and receipt of this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
Finding 2023-001 – ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL DOCUMENTATION Type: Significant Deficiency in Internal Control / Noncompliance Program: Education Stabilization Fund (ALN 84.425) – COVID 19 - all project numbers Condition: The District was unable to provide a semi-annual time certification, or equivalent documentation, for 8 of the 8 payroll transactions tested. Criteria: 2 CFR 200.430(i)(1)(viii) states that entities must, “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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.” Cause: Management oversight. Effect: As a result of this condition, the District does not have required payroll support for transactions tested which were charged to the grant. Questioned Costs: The total charges included in our sample that were not supported by allowable documentation amounted to $59,925. Recommendation: We recommend that the District review their policies and procedures regarding the documentation requirements of the grant and make the necessary changes, if needed, to assure that semi-annual time certifications (or equivalent documentation) are obtained. Management’s Resp: We are in agreement with this finding.
A. Finding on Internal Control over Compliance Finding Reference: 2023-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, where required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2022-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if thless than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
A. Finding on Internal Control over Compliance Finding Reference: 2023-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, where required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2022-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if thless than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Finding 2023-001 – Special Education Cluster (IDEA) AL# 84.027, 84.173; Federal Agency – U.S. Department of Education; Pass-through Agency – New York State Department of Education; Grant period – July 1, 2022 – June 30, 2023 Condition: The School District did not have a control in place to ensure that there was adequate documentation, in accordance with 2 CFR section 200.430, of the distribution of an employee’s salary among specific activities when an employee worked on both a Federal award and a non- Federal award. Certification of Federal Award forms were prepared, but they did not indicate the fulltime equivalent (FTE) time to be allocated to the grant and they were not reviewed. Criteria: The Department of Education Cross-Cutting Section of the 2023 Compliance Supplement indicates, “if a school operating a schoolwide program does not consolidate Federal funds with State and local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on a Federal program or cost objective must document time and effort as follows: (a) For an employee who works solely on a single cost objective (e.g., a single Federal program whose funds have not been consolidated or Federal programs whose funds have been consolidated but not with State and local funds), an LEA is not required to maintain records reflecting the distribution of the employee’s salary and wages, including among the Federal programs included in the consolidation, if applicable. (b) For an employee who works on multiple activities or cost objectives (e.g., in part on a Federal program whose funds have not been consolidated in a consolidated schoolwide pool and in part on Federal programs supported with funds consolidated in a schoolwide pool or on activities that are not part of the same cost objective), an LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: i. The Federal program or cost objective; and ii. Each other program or cost objective supported by consolidated Federal funds or other revenue sources. Cause: There was turnover in the Chief Executive Director of HR & Grants Management position, and as such, there was no position clearly tasked with the responsibility of reviewing the Certification of Federal Award forms during the year. Effect: The School District could have claimed grant reimbursement for an employee when the employee may not have actually worked hours related to, or allowable under, that program. Context: The School District indicated that the Certification of Federal Award forms were not reviewed for any of the employees charged to the grants under the Special Education Cluster. Auditor’s Recommendation: The School District should implement a process in which employee’s time is documented on the Certification of Federal Award forms and the forms are reviewed by an individual with sufficient knowledge about the employee’s duties and the Federal program in order to ensure the costs are allowable and adequately documented. View of Responsible Officials and Planned Corrective Actions: The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Federal Agency: U.S. Department of Education Federal Program: Education Stabilization Fund ALN(s): 84.425U Pass-through Agency: Michigan Department of Education Grant Number(s): 213713 Project 2122; 213723 Project 2122 Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed. Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III. Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff. Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations. Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs. Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages with regard to budget estimates used for interim accounting purposes. At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports should be made. Costs charged to federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent. The budget estimates should be revised at least quarterly, if necessary, to reflect changed circumstances. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the budget estimates were reviewed quarterly and the costs charged to the federal program were adjusted based on the activity actually performed. Recommendation: The Institute should implement procedures to ensure any budget estimates used for salaries and wages are reviewed quarterly and adjusted to reflect actual cost for the activity performed in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
Criteria: Section 200.430 of 2 CFR Part 200 states standards for documentation for personnel expenses for the support of federal salaries and wages. Condition/Effect: The Institute did not fully comply with the South Carolina Department of Education’s (“SCDE”) requirements for support for federal salaries and wages for this program. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PAR). This is required when employees work on more than one Federal award, a Federal award and a non-Federal award, an indirect cost and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. The PARS are required to meet the following standards: they must reflect an after the fact distribution of the actual activity of each employee, they must account for the total activity for which employee is compensated, they must be prepared at least monthly and coincide with one or more pay periods, and they must be signed by the employee. Cause: The Institute’s internal controls over salaries and wages charged to federal programs were not operating effectively to ensure that the documentation for federal salaries and wages were completed in accordance with the requirements. Questioned Costs: Not Determined Recommendation: The Institute should implement procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and has proactively taken action to ensure compliance with SCDE requirements. See management's corrective action plan.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Information on the Major Federal Program U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/ November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Criteria or Specific Requirements – In accordance with 2 CFR Section 200.430.8(i), charges to federal awards for salaries and wages must be based on records that reflect the actual work performed. The charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and must be incorporated into the official records of the non-Federal entity. Condition - Several charges to Federal awards for salaries and wages were not supported with properly completed time sheets and in certain instances, approval of the timesheets by individuals knowledgeable of the federal program were not documented. Cause - While there is a time keeping system implemented to track daily hours worked by employees, the Organization’s current internal control system over payroll is not consistently followed to produce properly completed time sheets nor proper supervisory approval of timesheets. Effect - Charges to Federal awards for salaries and wages may not reflect accurate time worked. Questioned costs - None Context - We selected 64 salary transactions charged to the federal programs to test controls over allowable costs. Out of the 64 transactions tested, there were 15 instances where controls did not operate effectively, i.e., timesheets were not properly completed to reflect correct number of days worked or timesheets were not properly approved by the employees’ supervisors. Repeat finding - No Recommendation - We recommend the Organization consistently enforce its internal controls over payroll to ensure that all timesheets are properly and timely completed and reviewed and verified by appropriate personnel for accuracy. Views of Responsible Officials - Management agrees with the federal award finding identified in the audit and effective immediately, will implement necessary procedures as described under the corrective action plan to address the finding. Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Retention of Files and Records - Criteria: CFR 200.430 Compensation - Records of salaries must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records should include timesheets, or other time records that are signed and approved by the appropriate personnel to confirm that the time is accurate. Condition and Context: In testing the compliance and accuracy of allowable payroll costs during the award year, it was noted that the Organization did not maintain certain appropriate documentation of time and effort, specifically timesheets showing the review and approval process for certain employees during the award year. Questioned Costs: None. Cause: The Organization has policies and procedures in place to ensure that the appropriate documentation for time and effort is maintained and supported by a system of internal control. However, in this case the procedures were not adhered due to turnover in key employees and change in payroll providers. Effect: The absence of documentation that supports the review and approval process of time and effort reporting makes it difficult for management to substantiate that the payroll charges are accurate and could lead to non-compliance with Federal requirements. Perspective Information: We tested 25 timesheets. Of those selections 1 timesheet was missing and 1 timesheet did not have the proper approval. The sampling methodology used was a statistically valid sample. Recurring Finding: No. Recommendation:We recommend that the Organization modify its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84,027, 84.173 Federal Award Identification Number: N/A Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131 Award Period: July 1, 2021 – June 30, 2023 Compliance Requirement: Allowable Costs / Cost Principles Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: Three (3) of nine (9) payroll transactions in our statistically valid sample were not supported with documentation of level of effort for the grant. Questioned costs: • Known: $13,438 • Likely: $96,278 Cause: Procedures were not in place to ensure that supporting payroll records accurately reflected the time and effort charged to the program. Effect: Noncompliance with federal compliance requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be implemented to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program. Views of responsible officials: Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.
Federal Agency: U.S. Department of Education Federal Program Name: ESSER I Assistance Listing Number: 84.425D Federal Award Identification Number: N/A Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 113-397270-2021-0131 Award Period: July 1, 2021 – June 30, 2023 Compliance Requirement: Allowable Costs / Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: Ten (10) of ten (10) payroll transactions in our statistically valid sample were supported by records which accurately reflected the work performed. However, such records did not include documented evidence of review and approval which would provide reasonable assurance that the charges were accurate, allowable, and properly allocated. Questioned costs: Below the reportable limit Cause: Procedures were not in place to ensure the payroll records were supported by the Town’s internal controls. Effect: Federal funds could be expended for unallowable activities and subject to disallowance. Repeat Finding: Yes, 2022-002 Recommendation: We recommend procedures be implemented to ensure that the records supporting payroll charges to the federal grant program include documented evidence of review and approval. Views of responsible officials: The Hingham Public School's general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.
2023-002 – Internal Controls over Compliance with Documentation of Personnel Expenses Finding Type: Significant Deficiency in Internal Control over Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Allowable Costs/Cost Principles Criteria: 2 CFR Part 200.430(i) Standards for Documentation of Personnel Expenses requires that 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and 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. Condition: The District did not appropriately reflect the federal awards for which certain employee salaries and wages were charged, including the improper use of a semi-annual certification and timesheets that do not depict the federal award from which the salaries and wages are paid. Cause: The District failed to ensure pre-filled forms were not used for certain employees being charged to federal awards. In addition, the District failed to fully understand the appropriate uses of a semi-annual certification. Effect: Failure to properly document personnel expenses could result in non-compliance and dis-allowed costs, resulting in the loss of federal funds. Auditor’s Recommendations: It is recommended that the District communicate to all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. In addition, the District should review the requirement for personnel activity reports and semi-annual certifications to ensure the use of either is appropriate in each circumstance.
2023-002 – Internal Controls over Compliance with Documentation of Personnel Expenses Finding Type: Significant Deficiency in Internal Control over Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Allowable Costs/Cost Principles Criteria: 2 CFR Part 200.430(i) Standards for Documentation of Personnel Expenses requires that 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and 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. Condition: The District did not appropriately reflect the federal awards for which certain employee salaries and wages were charged, including the improper use of a semi-annual certification and timesheets that do not depict the federal award from which the salaries and wages are paid. Cause: The District failed to ensure pre-filled forms were not used for certain employees being charged to federal awards. In addition, the District failed to fully understand the appropriate uses of a semi-annual certification. Effect: Failure to properly document personnel expenses could result in non-compliance and dis-allowed costs, resulting in the loss of federal funds. Auditor’s Recommendations: It is recommended that the District communicate to all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. In addition, the District should review the requirement for personnel activity reports and semi-annual certifications to ensure the use of either is appropriate in each circumstance.
2023-002 – Internal Controls over Compliance with Documentation of Personnel Expenses Finding Type: Significant Deficiency in Internal Control over Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Allowable Costs/Cost Principles Criteria: 2 CFR Part 200.430(i) Standards for Documentation of Personnel Expenses requires that 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 which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and 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. Condition: The District did not appropriately reflect the federal awards for which certain employee salaries and wages were charged, including the improper use of a semi-annual certification and timesheets that do not depict the federal award from which the salaries and wages are paid. Cause: The District failed to ensure pre-filled forms were not used for certain employees being charged to federal awards. In addition, the District failed to fully understand the appropriate uses of a semi-annual certification. Effect: Failure to properly document personnel expenses could result in non-compliance and dis-allowed costs, resulting in the loss of federal funds. Auditor’s Recommendations: It is recommended that the District communicate to all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. In addition, the District should review the requirement for personnel activity reports and semi-annual certifications to ensure the use of either is appropriate in each circumstance.
Finding 2023-002: Special Education Cluster Semi-Annual Certification Procedures U.S. Department of Education Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.027A, 84.027X, 84.173A and 84.173X Award numbers: 220450 21-22, 230493 22-23, 230450 22-23, COVID-19 221280 21-22, 220460 21-22, 230460 22-23 and COVID-19 221285 21-22 Award year ends: June 30, 2023, September 30, 2023 and September 30, 2024 Specific Requirement: Allowable Costs/Cost Principles Criteria: Section 200.430 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. Appendix B to 2 CFR, Part 225—Selected Items of Cost indicates that where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Questioned Costs: None. Condition: During our detailed testing of time-and-effort reporting for the Special Education Cluster programs, we noted that semi-annual certifications were prepared to comply with federal time and effort requirements. However, the reports were not timely prepared or timely reviewed by the program supervisors with documented approval. Context: Eighteen employees working in the federal program were eligible for semi-annual certifications because their payroll costs were fully allocated to a single federal program or cost objective. Separate semi-annual certifications were prepared for each eligible employee for each six-month period during the fiscal year. While all certifications contained the proper components, including documented supervisor approval, they were not prepared timely as the forms for fourteen employees were completed and certified at least two-and-a-half or three-and-a-half months after the six-month period ending dates. Additionally, both semi-annual certifications for four employees were approved during the audit process. The sample was not a statistically valid sample. Effect: Failure to timely and properly prepare and review time-and-effort reporting could allow improper payroll expenses to be charged to the School District’s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The School District program personnel did not timely review and approve the federal requirements for time-and-effort reporting semi-annual certifications. As a result, semi-annual certifications were not reviewed and approved for these employees during the required timeframes. Repeat Finding: This is not a repeat finding. Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Views of Responsible Officials: The School District agrees with this finding.
Finding 2023-002: Special Education Cluster Semi-Annual Certification Procedures U.S. Department of Education Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.027A, 84.027X, 84.173A and 84.173X Award numbers: 220450 21-22, 230493 22-23, 230450 22-23, COVID-19 221280 21-22, 220460 21-22, 230460 22-23 and COVID-19 221285 21-22 Award year ends: June 30, 2023, September 30, 2023 and September 30, 2024 Specific Requirement: Allowable Costs/Cost Principles Criteria: Section 200.430 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. Appendix B to 2 CFR, Part 225—Selected Items of Cost indicates that where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Questioned Costs: None. Condition: During our detailed testing of time-and-effort reporting for the Special Education Cluster programs, we noted that semi-annual certifications were prepared to comply with federal time and effort requirements. However, the reports were not timely prepared or timely reviewed by the program supervisors with documented approval. Context: Eighteen employees working in the federal program were eligible for semi-annual certifications because their payroll costs were fully allocated to a single federal program or cost objective. Separate semi-annual certifications were prepared for each eligible employee for each six-month period during the fiscal year. While all certifications contained the proper components, including documented supervisor approval, they were not prepared timely as the forms for fourteen employees were completed and certified at least two-and-a-half or three-and-a-half months after the six-month period ending dates. Additionally, both semi-annual certifications for four employees were approved during the audit process. The sample was not a statistically valid sample. Effect: Failure to timely and properly prepare and review time-and-effort reporting could allow improper payroll expenses to be charged to the School District’s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The School District program personnel did not timely review and approve the federal requirements for time-and-effort reporting semi-annual certifications. As a result, semi-annual certifications were not reviewed and approved for these employees during the required timeframes. Repeat Finding: This is not a repeat finding. Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Views of Responsible Officials: The School District agrees with this finding.
Finding 2023-002: Special Education Cluster Semi-Annual Certification Procedures U.S. Department of Education Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.027A, 84.027X, 84.173A and 84.173X Award numbers: 220450 21-22, 230493 22-23, 230450 22-23, COVID-19 221280 21-22, 220460 21-22, 230460 22-23 and COVID-19 221285 21-22 Award year ends: June 30, 2023, September 30, 2023 and September 30, 2024 Specific Requirement: Allowable Costs/Cost Principles Criteria: Section 200.430 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. Appendix B to 2 CFR, Part 225—Selected Items of Cost indicates that where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Questioned Costs: None. Condition: During our detailed testing of time-and-effort reporting for the Special Education Cluster programs, we noted that semi-annual certifications were prepared to comply with federal time and effort requirements. However, the reports were not timely prepared or timely reviewed by the program supervisors with documented approval. Context: Eighteen employees working in the federal program were eligible for semi-annual certifications because their payroll costs were fully allocated to a single federal program or cost objective. Separate semi-annual certifications were prepared for each eligible employee for each six-month period during the fiscal year. While all certifications contained the proper components, including documented supervisor approval, they were not prepared timely as the forms for fourteen employees were completed and certified at least two-and-a-half or three-and-a-half months after the six-month period ending dates. Additionally, both semi-annual certifications for four employees were approved during the audit process. The sample was not a statistically valid sample. Effect: Failure to timely and properly prepare and review time-and-effort reporting could allow improper payroll expenses to be charged to the School District’s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The School District program personnel did not timely review and approve the federal requirements for time-and-effort reporting semi-annual certifications. As a result, semi-annual certifications were not reviewed and approved for these employees during the required timeframes. Repeat Finding: This is not a repeat finding. Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Views of Responsible Officials: The School District agrees with this finding.