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.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
Corporation for National and Community Services Assistance Listing Numbers 94.006 – AmeriCorps State and National Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: The Organization was unable to provide applicable payroll documentation for the period August 1, 2022 through July 31, 2023 in order to validate compliance and internal controls over Activities Allowed and Allowable Costs/Cost Principles as it relates to payroll charges to the Federal grant. Management charged payroll to the program based on budget. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per AmeriCorps general terms and conditions, the recipient must maintain financial management systems that comply with 2 CFR § 200.302(b). The recipient’s financial management systems must be capable of distinguishing expenditures attributable to this award from expenditures not attributable to this award. The systems must be able to identify costs by program year and by budget category, and to differentiate between direct and indirect costs. For all recipient’s financial management requirements and responsibilities, refer to Subparts D and E of 2 CFR Part 200. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
U.S. Department of Treasury Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds Compliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: During our testing of payroll transactions for the program, we noted 24 out of 40 exceptions. For 16 selections, we did not receive the timesheets to substantiate the amount charged to the grant. We were unable to determine whether the salaries that were charged to the program accurately reflect the actual effort on the program. For 8 selections, the employees and tutors were assigned to a single cost objective for the grant, thus, not showing the effort by funding source, which is needed to calculate the actual effort for this Federal grant. Criteria: The Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control-Integrated Framework (COSO Report), published by the Committee of Sponsoring Organizations of the Treadway Commission. The COSO Report provides a framework for organizations to design, implement, and evaluate control that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 2 CFR section 200.430(a)(3)(i): (a) General. Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: The Organization did not have adequate controls over the time and effort process, therefore recording and retention of supporting documentation was not properly adhered to in accordance with Uniform Guidance. Effect or Potential Effect: Salaries and wages were not properly supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Salary and wage charges were not able to be reconciled to the time distribution records. Questioned Costs: Unknown. Recommendation: We recommend that the Organization implement policies and procedures to track, calculate and document adjustments from budget salary charges to actual after-the-fact charges that should be charged to the Federal award based on the employee time distribution records. This needs to be performed at least on an annual basis.
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.
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.
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.