FINDING 2022-003 INADEQUATE SUPPORT FOR SALARIES AND WAGES- TIME CERTIFICATIONS NOT MAINTAINED (50000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425, D, U). Title I (Assistance Listing 84.010) Criteria: 2 CFR 200.430 requires that an LEA must maintain time and effort distribution records that support the distribution of the employee?s salary or wages among specific activities or cost objectives. 2CFR, section 225, appendix B, Section 8(h) states in part: Support of salaries and wages?These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for salaries and wages of employees who work in a single indirect cost activity. (3) 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 employee worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. 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: The District provided approved time sheets for only 3 employees out of 20 selected that were paid from ESSER funding. The District provided 9 of 10 time accounting records that included PARS for Title I. Context/Questioned Cost/Effect: The District did not provide time certification records for 17 of the 20 employees selected for review, who were paid with Education Stabilization Funds. As a result, the amount of $736,116.27 is in question. This finding occurred in the 2021-22 fiscal year and is not a repeat finding. The District did not provide time certification records for 1 of 8 employees selected for review, who was paid with Title I funds, as a result, the amount of $ 91,794 is in question. 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. Recommendations: We recommend the District comply with Title 2, CFR 200.303, and CSAM Procedure 905 which require that employee time certification forms be maintained for employees who charge time to federal programs. Views of Responsible Officials: Management will ensure that the District does have adequate controls in place and comply with Federal rules and guidelines.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Assistance Listing Number, Federal Agency, and Program Name - ALN 17.207 Employment Service Cluster and ALN 17.258, 17.259, and 17.278 WIOA Cluster Federal Award Identification Number and Year - Various Pass-through Entity - Michigan Department of Labor and Economic Opportunity - Workforce Development Agency Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.430(a)(3) indicates that personal services are allowable to the extent they are determined and supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition - An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Five of the six personnel files that were provided as support for pay rates appeared to contain outdated information. Cause and Effect - DESC did not have a control in place to maintain current payrates in personnel files or to provide alternative documentation to support that pay rates were approved. As a result, we were not able to determine if the rates of pay were approved by management. Recommendation - DESC should maintain up-to-date personnel information to support that the rates of pay for employees are approved. Views of Responsible Officials and Planned Corrective Actions - DESC was unable to locate evidence due to turnover with the HR department. We have hired a new director of human resources (the "Director"), who has implemented an employee filing system that incorporates up-to-date employee information and salary information. This information is noted in offer letters, promotion letters, and salary increase letters. All payroll updates are required in writing to evidence approval of the Director and another executive team member's authorization (president or CFO). This confidential information is stored in the Director?s locked office.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states 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. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for 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. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 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. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for 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. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 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. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for 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. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 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. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for 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. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 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. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for 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. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 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. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. There were 4 of 53 disbursements charged to the grant fund that were not in compliance with the Allowable Costs/Cost Principles compliance requirement. The 4 issues identified were as follows: 1. The School Corporation paid one employee's salary without supporting documentation or personnel reports, such as time and effort logs to support the time charged to the grant. 2. The School Corporation paid three employees a rate of pay not supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 32 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. There were 4 of 53 disbursements charged to the grant fund that were not in compliance with the Allowable Costs/Cost Principles compliance requirement. The 4 issues identified were as follows: 1. The School Corporation paid one employee's salary without supporting documentation or personnel reports, such as time and effort logs to support the time charged to the grant. 2. The School Corporation paid three employees a rate of pay not supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 32 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control 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 (for IHE, this per the IHE's definition of IBS); . . . (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; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234