2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or 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: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or 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: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or 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: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or 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: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or 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: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2023-033 (other noncompliance / significant deficiency – repeat finding – 2022-059) WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS AND CHILDREN – 10.557 Federal Awarding Agency: U.S. Department of Agriculture (USDA), Food and Nutrition Service Federal Award Fiscal Years: 2022 and 2023 Federal Award Numbers: 224RI705W1003, 224RI705W1006, 234RI705W1003, 234RI705W1006 Administered by: Rhode Island Department of Health (RIDOH) EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) – 93.323 Federal Awarding Agency: U.S. Department of Health and Human Services (HHS) Federal Award Fiscal Years: 2019-2024 Federal Award Number: NU50CK000519 Administered by: Rhode Island Department of Health (RIDOH) Compliance Requirements: Allowable Costs/Cost Principles TIME AND EFFORT REPORTING RIDOH can enhance controls over time and effort reporting to ensure accurate allocations and reimbursements from federal programs. Background: RIDOH has built a robust, yet complex, time reporting worksheets for employees to allocate their time spent on various activities during the week. Reconciliation of the hours worked versus the hours charged to the State’s payroll system and accounting system is performed on a quarterly basis. Amounts recorded are adjusted accordingly to ensure charges in the accounting system are consistent with actual time charged to various programs. Criteria: 45 CFR §75.430(i)(1) and 2 CFR §200.430(i)(1) require that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” Condition: Our review of personnel costs identified the following deficiencies that weaken controls over the allowability of personnel expenditures: • Amounts allocated to federal programs for personnel costs were not consistently supported by properly signed and reviewed timesheets. While RIDOH was able to provide timesheets for all selected pay periods, for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, 6 of the 80 selected weekly timesheets lacked a supervisor signature. This was considered a control deficiency, but not noncompliance since the employee reported time and effort which supported allocation to the ELC program. • One individual noted in our ELC payroll sample (4 weekly time sheets) did not have their recorded payroll adjusted through the subsequent quarterly entry to accurately reflect work performed on federal programs. This resulted in payroll costs being overallocated to the ELC program (questioned costs - $3,355). • For both ELC and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), we noted time and effort recorded to generalized timesheet category codes (i.e., Administrative Support, Finance and Operations, ICS – Incident Command System) lacked sufficient detail (i.e., underlying activity performed in support of related category code) to support its specific federal program allocation. Questioned costs could not be determined due to the lack of time and effort detail reported. Cause: Policies and procedures were ineffective to ensure amounts claimed and reimbursed by federal programs for personnel costs were reflective of the actual work performed on the various programs/projects listed. The State’s lack of sufficient timesheet detail prevented direct verification of recorded timesheet activities to the underlying charges on federal programs. Effect: Personnel costs reimbursed from federal awards could be unallowable due to insufficient support and documentation. Questioned Costs: $3,355 (ELC – 93.323) Valid Statistical Sampling: Yes RECOMMENDATION 2023-033 Enhance weekly reporting of time and effort to improve documentation and support for personnel costs charged to federal programs. Auditee views: The auditee concurs with this finding – see Corrective Action Plan in Section E.
Finding 2023-039 (other noncompliance / significant deficiency – new finding) CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – 21.027 Federal Awarding Agency: U.S. Department of The Treasury (TREAS) Federal Award Fiscal Years: 2021 to 2025 Federal Award Number: SLFRP0136 Administered by: Rhode Island Department of Administration, Pandemic Recovery Office (PRO) Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles TIME AND EFFORT REPORTING The Pandemic Recovery Office’s time and effort reporting for the State Fiscal Recovery Fund (SFRF) did not provide adequate detail to fully support certain personnel costs charged to the program. Background: PRO instituted time reporting worksheets for employees to allocate their time spent on SFRF-related activities during the week. On a weekly basis, the agency compares its “Master Timesheet” to each employee’s timesheet for the purpose of recording an adjusting journal entry. This entry is recorded to adjust payroll expenditures in accordance with actual time spent on program activities. Criteria: 2 CFR §200.430(i)(1) requires that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” Condition: Our review of payroll costs identified the following deficiencies that weaken controls over the allowability of personnel expenditures: • During the examination of payroll allocations charged to the program, we identified that one employee’s payroll costs continued to be charged in full to SFRF for 5 pay periods subsequent to their departure from the PRO. PRO did not identify and adjust for this exception during fiscal 2023 (questioned costs - $34,533). • PRO maintains a Master Timesheet for all its employees and asserts that only individuals listed on the Master Timesheet are eligible to submit payroll charges against SFRF. We noted one employee charged to the program for whom, upon review of the employee time records, no work hours under the SFRF program were reported. While it was explained that this employee was partially dedicated to performing SFRF activities within the Division of Purchasing, no time sheet documentation was provided in support of SFRF activities (questioned costs - $13,132). • During the review of timesheets for PRO supervisory approval, it was noted that several employee timesheets received approval from their supervisors one, two, and in some instances, three days prior to the conclusion of the pay period. This observation raises concerns regarding the timeliness and accuracy of time reporting, potentially impacting the integrity of payroll processing and adherence to internal controls over timekeeping procedures. According to the PRO, this is due to the Department of Administration’s routine request for submission of timesheets prior to the end of the period. If PRO identifies an instance that requires an amendment to the original timesheet, an amended timesheet will be submitted subsequently. Cause: Insufficient controls over the claiming of personnel expenditures to ensure adequate controls are in place to ensure compliance with federal requirements (i.e., adequate documentation of time and effort). Effect: Personnel expenditures could be unallowable due to a lack of adequate support and/or inaccurate allocation of expenditures to the SFRF program. Questioned Costs: $47,655 Valid Statistical Sampling: Yes RECOMMENDATIONS 2023-039a Conduct regular reconciliation and monitoring of payroll charges to agency records to improve documentation and support for personnel costs charged to federal programs. 2023-039b Modify current policies relating to timesheet collection to ensure that supervisory reviews of time and effort reporting are accurate and complete. Auditee views: The auditee partially disagrees with this finding – see Corrective Action Plan in Section E.
Finding 2023-033 (other noncompliance / significant deficiency – repeat finding – 2022-059) WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS AND CHILDREN – 10.557 Federal Awarding Agency: U.S. Department of Agriculture (USDA), Food and Nutrition Service Federal Award Fiscal Years: 2022 and 2023 Federal Award Numbers: 224RI705W1003, 224RI705W1006, 234RI705W1003, 234RI705W1006 Administered by: Rhode Island Department of Health (RIDOH) EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) – 93.323 Federal Awarding Agency: U.S. Department of Health and Human Services (HHS) Federal Award Fiscal Years: 2019-2024 Federal Award Number: NU50CK000519 Administered by: Rhode Island Department of Health (RIDOH) Compliance Requirements: Allowable Costs/Cost Principles TIME AND EFFORT REPORTING RIDOH can enhance controls over time and effort reporting to ensure accurate allocations and reimbursements from federal programs. Background: RIDOH has built a robust, yet complex, time reporting worksheets for employees to allocate their time spent on various activities during the week. Reconciliation of the hours worked versus the hours charged to the State’s payroll system and accounting system is performed on a quarterly basis. Amounts recorded are adjusted accordingly to ensure charges in the accounting system are consistent with actual time charged to various programs. Criteria: 45 CFR §75.430(i)(1) and 2 CFR §200.430(i)(1) require that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” Condition: Our review of personnel costs identified the following deficiencies that weaken controls over the allowability of personnel expenditures: • Amounts allocated to federal programs for personnel costs were not consistently supported by properly signed and reviewed timesheets. While RIDOH was able to provide timesheets for all selected pay periods, for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, 6 of the 80 selected weekly timesheets lacked a supervisor signature. This was considered a control deficiency, but not noncompliance since the employee reported time and effort which supported allocation to the ELC program. • One individual noted in our ELC payroll sample (4 weekly time sheets) did not have their recorded payroll adjusted through the subsequent quarterly entry to accurately reflect work performed on federal programs. This resulted in payroll costs being overallocated to the ELC program (questioned costs - $3,355). • For both ELC and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), we noted time and effort recorded to generalized timesheet category codes (i.e., Administrative Support, Finance and Operations, ICS – Incident Command System) lacked sufficient detail (i.e., underlying activity performed in support of related category code) to support its specific federal program allocation. Questioned costs could not be determined due to the lack of time and effort detail reported. Cause: Policies and procedures were ineffective to ensure amounts claimed and reimbursed by federal programs for personnel costs were reflective of the actual work performed on the various programs/projects listed. The State’s lack of sufficient timesheet detail prevented direct verification of recorded timesheet activities to the underlying charges on federal programs. Effect: Personnel costs reimbursed from federal awards could be unallowable due to insufficient support and documentation. Questioned Costs: $3,355 (ELC – 93.323) Valid Statistical Sampling: Yes RECOMMENDATION 2023-033 Enhance weekly reporting of time and effort to improve documentation and support for personnel costs charged to federal programs. Auditee views: The auditee concurs with this finding – see Corrective Action Plan in Section E.
Finding 2023-033 (other noncompliance / significant deficiency – repeat finding – 2022-059) WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS AND CHILDREN – 10.557 Federal Awarding Agency: U.S. Department of Agriculture (USDA), Food and Nutrition Service Federal Award Fiscal Years: 2022 and 2023 Federal Award Numbers: 224RI705W1003, 224RI705W1006, 234RI705W1003, 234RI705W1006 Administered by: Rhode Island Department of Health (RIDOH) EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) – 93.323 Federal Awarding Agency: U.S. Department of Health and Human Services (HHS) Federal Award Fiscal Years: 2019-2024 Federal Award Number: NU50CK000519 Administered by: Rhode Island Department of Health (RIDOH) Compliance Requirements: Allowable Costs/Cost Principles TIME AND EFFORT REPORTING RIDOH can enhance controls over time and effort reporting to ensure accurate allocations and reimbursements from federal programs. Background: RIDOH has built a robust, yet complex, time reporting worksheets for employees to allocate their time spent on various activities during the week. Reconciliation of the hours worked versus the hours charged to the State’s payroll system and accounting system is performed on a quarterly basis. Amounts recorded are adjusted accordingly to ensure charges in the accounting system are consistent with actual time charged to various programs. Criteria: 45 CFR §75.430(i)(1) and 2 CFR §200.430(i)(1) require that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” Condition: Our review of personnel costs identified the following deficiencies that weaken controls over the allowability of personnel expenditures: • Amounts allocated to federal programs for personnel costs were not consistently supported by properly signed and reviewed timesheets. While RIDOH was able to provide timesheets for all selected pay periods, for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, 6 of the 80 selected weekly timesheets lacked a supervisor signature. This was considered a control deficiency, but not noncompliance since the employee reported time and effort which supported allocation to the ELC program. • One individual noted in our ELC payroll sample (4 weekly time sheets) did not have their recorded payroll adjusted through the subsequent quarterly entry to accurately reflect work performed on federal programs. This resulted in payroll costs being overallocated to the ELC program (questioned costs - $3,355). • For both ELC and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), we noted time and effort recorded to generalized timesheet category codes (i.e., Administrative Support, Finance and Operations, ICS – Incident Command System) lacked sufficient detail (i.e., underlying activity performed in support of related category code) to support its specific federal program allocation. Questioned costs could not be determined due to the lack of time and effort detail reported. Cause: Policies and procedures were ineffective to ensure amounts claimed and reimbursed by federal programs for personnel costs were reflective of the actual work performed on the various programs/projects listed. The State’s lack of sufficient timesheet detail prevented direct verification of recorded timesheet activities to the underlying charges on federal programs. Effect: Personnel costs reimbursed from federal awards could be unallowable due to insufficient support and documentation. Questioned Costs: $3,355 (ELC – 93.323) Valid Statistical Sampling: Yes RECOMMENDATION 2023-033 Enhance weekly reporting of time and effort to improve documentation and support for personnel costs charged to federal programs. Auditee views: The auditee concurs with this finding – see Corrective Action Plan in Section E.
Reference Number: 2023-007 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Department of Human Services Federal Program: Rehabilitation Services - Vocational Rehabilitation Grants to States Assistance Listing Number: 84.126 Award Number and Year: H126A230044 (10/1/2022-9/30/2023) H126A230044-A (10/1/2022-9/30/2023) H126A230044-B (10/1/2022-9/30/2023) H126A210043 (10/1/2020-9/30/2022) H126A220043-22C (10/1/2021-9/30/2022) H126A230043 (10/1/2022-9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR § 200.430 (a), 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 or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, • Be incorporated into the official records of the non-Federal entity, • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, • 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, • Comply with the established accounting policies and practices of the non-Federal entity, • 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. Section III – Federal Award Findings and Questioned Costs (Continued) Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Human Services (Department) charged unallowable payroll costs to the program. Context: For one of forty samples selected for testing, the Department made an overpayment to an employee of $113.00 in salary and wages. Cause: Controls were not operating effectively to ensure that allowable payroll costs were charged to the program. A step increase was improperly applied to the employee which resulted in an overpayment of salary and wages. Effect: Unallowable employee salaries and wages were charged to the program. Questioned costs: $113.00, the amount of the overpayment. Recommendation: The Department should review procedures and controls to ensure that only allowable time and effort costs are charged to the program. Views of responsible officials: The Department of Human Services (DHS), Central Office Payroll group will run reports biweekly to determine if any employees are on a leave without pay status greater than 10 days. This added reporting function will ensure that all DHS employees who are on a leave of absence without pay beyond 10 days have their PMIS histories updated upon each extension and return to work.
Criteria: 2 CFR, section 200.430 states, in part: (i) 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: (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR, section 200.303 states, in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: be prepared at least semiannually. Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective. Personnel Activity Report Except as provided in “Substitute Systems for Time Accounting” employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach is to provide more documentation rather than less. Condition: We identified 15 employees whose salaries were charged to Education Stabilization Funds but the District was unable to provide time accounting documentation for the 2022-23 fiscal year. Context: Exceptions were discovered in all 15 employees sampled. Questioned Costs: Total questioned cost for the 15 employees is $66,793. Cause: The District does not have adequate controls in place to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: District may be overcharging the Education Stabilization funds for time which isn’t spent directly working on the program. Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905, which require that employee time certification forms be maintained for employees who charge time to federal program. Views of Responsible Officials: Starting April 1, 2024, Keppel Union School District will require all employees funded by more than one resource to fill out a PAR Form. The District will require those funded by one restricted resource to be covered by a blanket semi-annual PAR Form.
Criteria According to Section 2 CFR Part 200.430 (i) Standard for Documentation of Personnel Expenses, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records 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 a 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 Controls were inadequate to ensure the Organization maintains timekeeping documentation by grant. Context During the testing of the allowability of expenses, we discovered personnel expenses were charged to the incorrect grant cost center. Management allocates actual personnel expenses based on the grant budgeted amount instead of actual hours worked by the grant area. Management does not require personnel to track actual time spent by the grant. Cause and Effect The Organization did not fully follow the guidance detailed in Section 2 CFR Part 200.430 to ensure that payroll expense allocations are based on actual time spent instead of grant budgeted amounts.
Condition: There was an individual who had formerly worked for the Foundation in the previous fiscal year that was an employee of one of the Foundation’s partner agencies during the year under audit. This individual was compensated $20,000 through the Foundation’s payroll system during the year ended June 30, 2023, although she was no longer an employee of the Foundation. This payment was supported by an invoice from the former employee for hours worked between July and October of 2022 at her new employer related to this major program. There was no documented approval by the partner agency. This payment was charged as salaries to the major program. In addition, there was only one employee (program manager) who charged time to the major program, except as noted in the preceding paragraph. There was no authorized rate of pay on file for this employee. Criteria: In accordance with 2 CFR 200.430(i), payroll costs charged to federal awards must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA), charges for the salaries and wages of nonexempt employees must also be supported by records indicating the total number of hours worked each day. Cause and effect: Management believed the individual was undercompensated by her current employer, who is a subcontractor of the Foundation, for time spent on the major program. This additional payment was reported to the State of Arizona by management when paid. Recommendation: I recommend that an authorized rate of pay be included in all employees’ human resources files. Any independent contractors should be compensated as such, based on approved contracts, and charged to federal grants accordingly. Views of Responsible Officials: The Foundation confirms all employees have rate of pay documentation in their employee files. The Foundation is developing and will implement stronger policies around contractors engaged with the organization with oversight to contractors pay provided by the staffed CEO.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Lack of Time and Effort Documentation for Personnel Costs Condition: During the audit period, it was discovered that the School Department did not maintain appropriate time and effort documentation for employees whose salaries are charged, in whole or in part, to federal awards. Criteria: According to Uniform Guidance (2 CFR 200.430(i)), for salaries and wages to be charged to federal awards, records must accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Cause: The City did not follow their established internal control system that requires time and effort reports or equivalent documentation to be completed and maintained for employees engaged in federally funded activities. Effect: The lack of proper time and effort documentation raises the risk of misstating salary expenses charged to federal programs and may result in questioned costs due to noncompliance with federal regulations. Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future. Additionally, training should be provided to ensure that all personnel are aware of documentation requirements. Views of Responsible Officials and Planned Corrective Actions: Please see submitted corrective action plan for views of responsible officials and planned corrective actions.
Finding 2023-013 – B. Allowable Costs/Cost Principles Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859) Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented. Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award. Cause - Administrative oversight and insufficient internal control. Effect or Potential Effect – Noncompliance with documentation of personnel expense standards. Questioned Costs – Below reportable threshold. Context – Context is as follows: Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls. Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award. Indication of Repeat Finding - No similar findings noted in the prior year. Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained. Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Finding 2023-013 – B. Allowable Costs/Cost Principles Information on Federal Program(s) – Research and Development Cluster (ALN 43.009, ALN 93.859) Criteria or Specific Requirement - 2 CFR §200.430(i)(1)(i) indicates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR §200 requires that costs charged to programs are adequately documented. Condition – The summary level hourly documentation retained for payroll expenditures charged to the program was not formally supported with an adequate system of internal controls. Additionally, for certain non-payroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award. Cause - Administrative oversight and insufficient internal control. Effect or Potential Effect – Noncompliance with documentation of personnel expense standards. Questioned Costs – Below reportable threshold. Context – Context is as follows: Expenditures: For 2 of 2 months tested, the summary level hourly documentation retained was not formally supported with an adequate system of internal controls. Nonpayroll Expenditures: For 3 of 6 direct nonpayroll expenditures selected for testing, the University was unable to provide documentation adequately supporting the amount charged to the federal award. Indication of Repeat Finding - No similar findings noted in the prior year. Recommendation – We recommend that the University enhance its internal controls over compliance to ensure that time and effort records are appropriately maintained. Views of Responsible Officials – The University acknowledges that the records to substantiate the payroll and nonpayroll costs were insufficient and lacking internal controls. Going forward the University plans to implement a strategic process to document expenditures associated with research and development cluster and its federal grants. All employees that work with the Challenger Learning Center will continue to have their hours worked documented in the Paycom payroll software. Payroll is processed on a biweekly basis, and therefore on biweekly basis the payroll costs from the Challenger Learning Center will be reimbursed to the University from the various Challenger Learning Center bank accounts. This will be done as a percentage of time worked for the NIH Grant, the NASA Grant, and the general Challenger Learning Center functions. Additionally, for nonpayroll expenditures, all documentation will be retained to adequately support the amounts expended.
Assistance Listing #: 93.243 Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. Condition: During fiscal year 2023, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs. Cause: Management was unaware that using budget estimates was not allowed without further reconciliation against actual time or effort activities. The fiscal year 2022 Uniform Guidance audit was not completed until April 2024, which did not allow for changes to be implemented during fiscal year 2023. Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort. Questioned Costs: N/A Repeat Finding: Yes Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis. Response: NFFCMH plans to implement changes overall to the Federation’s timekeeping processes to ensure that payroll costs accurately reflect the work performed and to reconcile and true up any budget estimates on a consistent basis.
Assistance Listing #: 93.243 Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time. Condition: During fiscal year 2023, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs. Cause: Management was unaware that using budget estimates was not allowed without further reconciliation against actual time or effort activities. The fiscal year 2022 Uniform Guidance audit was not completed until April 2024, which did not allow for changes to be implemented during fiscal year 2023. Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort. Questioned Costs: N/A Repeat Finding: Yes Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis. Response: NFFCMH plans to implement changes overall to the Federation’s timekeeping processes to ensure that payroll costs accurately reflect the work performed and to reconcile and true up any budget estimates on a consistent basis.
2023-003 – Allowable Costs/Cost Principles Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Substance Use Disorder Residential Treatment for Pregnant and Postpartum Women Assistance listing number: 93.243 Award year: 9/30/2018 – 9/29/2023 Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award, and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity. Condition: Accurate and complete records to support disbursements were not maintained for the program. We specifically noted the following: • SFRC is currently allocating payroll costs to the program based on budget estimates. There is not a process in place to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. • For one month during fiscal year 2023, the amounts charged to the program were not supported by wages paid to the employee (used as the basis for the amount allocated to the program). • For two of six non-payroll disbursements tested, the amount allocated to the program did not agree to the amount paid to the vendor. • Indirect costs charged to the program were not allocated correctly based on SFRC’s approved indirect cost rate. Context: 15 of 15 payroll transactions tested were allocated to the program based on budget estimates. Two of six non-payroll disbursements did not agree with source documentation. Questioned Costs: $33,429 Cause: SFRC has not developed a process to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. There was not adequate review of reimbursement requests to ensure that payroll and non-payroll disbursements agree with source documentation. Indirect costs were not charged to the program using the approved indirect cost rate for fiscal year 2023. Effect: SFRC may not be able to demonstrate that costs charged to federal programs are allowable. Auditor’s Recommendation: SFRC should implement a process of comparing actual time and effort of employees to SFRC’s budget estimates at least bi-annually. Alternatively, SFRC could require employees to report their actual daily time on federal awards to ensure amounts charged are accurate and properly allocated. SFRC should implement a review process of reimbursement requests to ensure that disbursements agree with source documentation, and that indirect costs are charged to the program accurately. Management’s Response: Management implemented a process to evaluate time spent each month. That allocation is used to classify actual salary paid to particular federal awards on a pay period basis.
Reference Number: 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster Assistance Listing Number: 14.218 Award Number and Period: B-22-UC-24-0011, B-20-UW-24-0011 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect 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; (vi) Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 1 of 40 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $1,260 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster Assistance Listing Number: 14.218 Award Number and Period: B-22-UC-24-0011, B-20-UW-24-0011 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect 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; (vi) Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 1 of 40 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $1,260 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-006 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19-Emergency Rental Assistance Assistance Listing Number: 21.023 Award Number and Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charge to Federal awards for salaries and wages must be based on records that accurately reflect 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; VI. Support the distribution of the employee's salary and 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. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and Effort Certifications were not documented in accordance with federal requirements. The County was unable to provide adequate support to validate actual payroll expenses charged to the federal program for 7 of 60 time and effort certifications tested. Cause: The County did not have adequate controls to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Questioned Costs: $11,045 Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are 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; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan