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.
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.
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.
Reference Number: 2022-012 Prior Year Finding: 2021-010 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Allowable Costs/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, ? Be incorporated into the official records of the non-Federal entity, ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, ? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, ? Comply with the established accounting policies and practices of the non-Federal entity, ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: One of sixty employee timesheets selected for testing did not use combination codes and the employee?s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee?s actual time and effort on the program. The program incurs direct payroll charges which represents approximately $5.8 million (17%) of total WIOA cluster spending. The Department implemented the use of combination codes within Self-Service Time and Attendance (SSTA), a module of the HR/CMS application in July 2019. Prior to this date, payroll was assigned to grants based on budgeted time and effort allocations maintained in the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). SSTA combination codes are used by employees to allocate and certify hours worked to Federal grants and employees? supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system will default to budgeted grant allocations entered into LCM. Cause: The Department?s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Payroll charges allocated to grants based on budgeted time and effort can result in federal reimbursements that are not reflective of actual time and effort working on a grant. Questioned costs: Undetermined. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-012 Prior Year Finding: 2021-010 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Allowable Costs/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, ? Be incorporated into the official records of the non-Federal entity, ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, ? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, ? Comply with the established accounting policies and practices of the non-Federal entity, ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: One of sixty employee timesheets selected for testing did not use combination codes and the employee?s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee?s actual time and effort on the program. The program incurs direct payroll charges which represents approximately $5.8 million (17%) of total WIOA cluster spending. The Department implemented the use of combination codes within Self-Service Time and Attendance (SSTA), a module of the HR/CMS application in July 2019. Prior to this date, payroll was assigned to grants based on budgeted time and effort allocations maintained in the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). SSTA combination codes are used by employees to allocate and certify hours worked to Federal grants and employees? supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system will default to budgeted grant allocations entered into LCM. Cause: The Department?s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Payroll charges allocated to grants based on budgeted time and effort can result in federal reimbursements that are not reflective of actual time and effort working on a grant. Questioned costs: Undetermined. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-012 Prior Year Finding: 2021-010 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Allowable Costs/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR ? 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, ? Be incorporated into the official records of the non-Federal entity, ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, ? Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy, ? Comply with the established accounting policies and practices of the non-Federal entity, ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (the Department) charged budgeted personnel costs to the program instead of actual costs due to errors coding employee timesheets. Context: One of sixty employee timesheets selected for testing did not use combination codes and the employee?s time was defaulted to a budgeted grant allocation. Therefore, the amount charged to the program was not based on the employee?s actual time and effort on the program. The program incurs direct payroll charges which represents approximately $5.8 million (17%) of total WIOA cluster spending. The Department implemented the use of combination codes within Self-Service Time and Attendance (SSTA), a module of the HR/CMS application in July 2019. Prior to this date, payroll was assigned to grants based on budgeted time and effort allocations maintained in the Labor Cost Management (LCM) module of the Massachusetts Management Accounting and Reporting System (MMARS). SSTA combination codes are used by employees to allocate and certify hours worked to Federal grants and employees? supervisors are required to perform a line-item review of hours spent on each grant before approving timesheets. If a timesheet is approved without the use of combination codes, the system will default to budgeted grant allocations entered into LCM. Cause: The Department?s controls were not operating effectively to ensure that time and effort reporting was performed in accordance with federal requirements. Effect: Payroll charges allocated to grants based on budgeted time and effort can result in federal reimbursements that are not reflective of actual time and effort working on a grant. Questioned costs: Undetermined. Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: Management agrees with the finding.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
2022-008 Education Stabilization Fund (ALN 84.425), Federal Department of Education Child Care and Development Block Grant (ALN 93.575, 92.596), Federal Department of Health and Human Services Passed through the California Department of Equation Noncompliance and material weakness in internal control over Federal compliance Code 40000, 50000 Compliance Requirements Affected: Activities (A) and Costs (B) Criteria The Uniform Guidance 2 CFR section 200.430 specifies the standards for documenting salaries and wages charged to federal programs. 2 CFR section 200.200 stipulates the standards for documenting that direct charges to federal awards are for allowable costs. Condition The District did not provide supporting documentation for all the samples requested to support the audit. Cause We believe the cause is the turnover of District personnel, leaving no single responsible person with sufficient accountability to ensure full compliance. Effect The District was unable to support that it complied with the terms and conditions of Federal grant agreements. Questioned Costs Known and likely questioned costs by program are as follows: ALN Known Likely 84.425 $97,810 $48,365,738 93.575, 92.596 $39,372 $6,711,381 Context Audit samples of which no documentation was provided are considered deviations. The following table shows the number of deviations with the audit sample per program: ALN Sample Size Number of Deviations 84.425 68 31 93.575, 92.596 47 28 Recommendation We recommend that the District assigns a single person responsible for ensuring compliance and providing supporting documentation to the auditors. Views of Responsible Official The District has not prepared a response as of the date of this report. Identification as a Repeat Finding This finding was not reported in the previous year's audit.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education_Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Section III ? Federal Award Findings and Questioned Costs (continued) FINDING 2022-003 (continued) Criteria: 2 CFR 200.303 states in part: ?The non-federal Entity must: (b) 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 the guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? 2 CFR 200.303 states in part: ?Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented?? 2 CFR 200.430(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); ? (iv) 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?? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation?s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Identification as a repeat finding, if applicable: Yes, see Finding 2020-001. Recommendation: As recommended, management implemented internal control procedures for the year ended June 30, 2022. Views of Responsible Officials: Management agrees with this finding and has implemented their corrective action plan.
Criteria: The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures, or standards of conduct as described in the following sections: Financial management (2 CFR 200.302) Payment (2 CFR 200.305) General procurement standards (2 CFR 200.318) Competition (2 CFR 200.319) Methods of procurement to be followed (2 CFR 200.320) Compensation ? personal services (2 CFR 200.430) Compensation ? fringe benefits (2 CFR 200.431) Transportation costs (2 CFR 200.474) Condition: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Cause: The Town was not aware of these requirements. Effect: The Town is not in compliance with the Uniform Guidance with respect to these written policies. Recommendation: We recommend that the Town update its policies and procedures to comply with the Uniform Guidance requirements mentioned above. Management?s Response: We agree that our existing policies do not explicitly address federal award compliance requirements. We will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Information on Federal Program(s) - U.S. Department of Agriculture Passed through Florida Department of Health CFDA Number: 10.558 CFDA Name: Child and Adult Care Food Program Criteria ? The Code of Federal Regulations (CFR) Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation. Additionally, CFR Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate and allowable. Condition ? During our testing of payroll disbursements, we noted that one of the 25 payroll expenditures selected for testing did not have a properly approved personnel action form documenting the employee?s pay rate. Cause - Policies and procedures were not appropriately adhered to in this instance to ensure a properly approved personnel action form was maintained to evidence this cost was allowable and that an appropriate level of review and approval was completed prior to charging this cost to a federal program. Effect or Potential Effect - We were unable to confirm the accuracy or completeness of the expense claimed as a federal expenditure. Questioned Costs - There are no questioned costs as the disbursement amount is under the threshold. Context ? We tested a sample of 25 payroll expense items and found one exception. The expense consisted of $262 in gross employee wages charged to the federal program for which properly approved supporting documentation for the employee?s pay rate was not available. Total expense charged to the federal program for this employee was $5,948. This is a condition identified per review of the Organization?s controls over compliance with specified requirements using a statistically valid sample. Recommendation - We recommend that the Organization review its controls over payroll disbursements to ensure that all employees have a personnel action form to document approved pay rates. Views of Responsible Officials ? Management was aware of the Organization?s manual process to approve and store physical copies of pay rate approval, which placed the Organization at risk of losing proper documentation especially when Management experienced high turnover in Human Resource Department. Beginning in September 2022, the Organization has modified this process to allow managers to virtually approve and store digital copies of pay rate documentation.
Information on Federal Program(s) - U.S. Department of Agriculture Passed through Florida Department of Health CFDA Number: 10.558 CFDA Name: Child and Adult Care Food Program Criteria ? The Code of Federal Regulations (CFR) Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation. Additionally, CFR Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate and allowable. Condition ? During our testing of payroll disbursements, we noted that one of the 25 payroll expenditures selected for testing did not have a properly approved personnel action form documenting the employee?s pay rate. Cause - Policies and procedures were not appropriately adhered to in this instance to ensure a properly approved personnel action form was maintained to evidence this cost was allowable and that an appropriate level of review and approval was completed prior to charging this cost to a federal program. Effect or Potential Effect - We were unable to confirm the accuracy or completeness of the expense claimed as a federal expenditure. Questioned Costs - There are no questioned costs as the disbursement amount is under the threshold. Context ? We tested a sample of 25 payroll expense items and found one exception. The expense consisted of $262 in gross employee wages charged to the federal program for which properly approved supporting documentation for the employee?s pay rate was not available. Total expense charged to the federal program for this employee was $5,948. This is a condition identified per review of the Organization?s controls over compliance with specified requirements using a statistically valid sample. Recommendation - We recommend that the Organization review its controls over payroll disbursements to ensure that all employees have a personnel action form to document approved pay rates. Views of Responsible Officials ? Management was aware of the Organization?s manual process to approve and store physical copies of pay rate approval, which placed the Organization at risk of losing proper documentation especially when Management experienced high turnover in Human Resource Department. Beginning in September 2022, the Organization has modified this process to allow managers to virtually approve and store digital copies of pay rate documentation.
FINDING 2022-003 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): S010A190014, S010A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 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 Allowable Costs/Cost Principles compliance requirement. Of 25 employees tested, 2 did not have supporting documentation or personnel reports, such as time and effort logs, to support the time charged to the grant. 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: . . . (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; INDIANA STATE BOARD OF ACCOUNTS 18 CONCORD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . ." Cause Management had not established a system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could 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 a system of internal controls to ensure compliance and comply with the grant agreement and 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 2022-003 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): S010A190014, S010A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters 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 Allowable Costs/Cost Principles compliance requirement. Of 25 employees tested, 2 did not have supporting documentation or personnel reports, such as time and effort logs, to support the time charged to the grant. 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: . . . (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; INDIANA STATE BOARD OF ACCOUNTS 18 CONCORD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. . . ." Cause Management had not established a system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could 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 a system of internal controls to ensure compliance and comply with the grant agreement and 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.
FAL No. and Name: FAL 84.425D Covid-19 - Elementary and Secondary School Emergency Relief Award Number: Fund 21FESSII-110593-01A Federal Agency: Arizona Department of Education Compliance Requirement: Allowable Costs Questioned Costs: None Criteria: In accordance with 2 CFR, ?200.430(i)(1)(i), the School should maintain records that are supported by a system of internal control which provides reasonable assurance that the charges are accurate. Condition and context: For one out of forty employees tested, changes made to the employee's compensation were not accurately documented in the employee's personnel file. Cause: The School needs to formalize its procedures to properly document changes made to employee compensation levels. Effect: The employee's compensation costs charged to the program where not accurately documented in their personnel file, however it was determined that they where paid the proper amount. Recommendation: To help ensure that when changes are made to compensation levels employees are accurately paid, the School should implement internal control policies and procedures that require updates being adequately documented in the employee's personnel file. Management's Corrective Action Plan is included at the end of this report.
2022-002 Internal Control over Compliance with Activities Allowed or Unallowed, Allowable Cost/Cost Principles ? Payroll Activities Information on the Major Federal Programs ? United States Department of Treasury Assistance Listing Number: 21.027 Assistance Listing Name: Coronavirus State and Local Fiscal Recovery Funds Passthrough Entity: State of Illinois, Department of Commerce and Economic Opportunity Program Title - Small Business Community Navigators Program Pass-through Entity Identifying Number - 21-483011 Sub-award Period - July 1, 2021 to June 30, 2022 National Endowment for the Humanities (NEH) Assistance Listing Number: 45.164 Assistance Listing Name: Promotion of the Humanities Public Programs Program Title - Telling the Full Story: Sustaining the Stewards of America?s Diverse Historic Places Award Number - ZOR-283411-21 Award Period - October 1, 2021 to September 30, 2023 Program Title - For the People by the People: Transforming National Trust Historic Sites through the Humanities Award Number - ZPP-283412-22 Award Period - October 1, 2021 to March 31, 2023 Criteria ? The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (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; (iv) Encompass both federally assisted and all other activities compensated by the non- Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During the audit, we noted that the Trust has a system of internal control by which every pay period, timesheets are submitted by each employee and approved by a supervisor. However, given the system limitations from the time-entry system, employees can only charge hours to their home department, and those employees who do not work solely on the federal program are not able to charge hours directly to the federal award through the system. Given the system limitations, program managers gathered documentation to evidence the hours and associated costs which should be charged to the federal award and recorded the corresponding personnel costs to the federal award through a journal entry; however, there was no direct evidence of review and approval of these personnel costs charged to the federal awards, other than an approval of the journal entry. While there was a lack of direct approval of hours charged to the federal program by program managers, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause ? The Trust?s system of internal control did not have procedures in place for program managers to approve the hours charged to the federal awards. Effect or Potential Effect ? Without direct approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over recording of time exists. Questioned Costs ? None. Context - This is a condition identified based upon our review of the Trust?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. Repeat finding ? This is not a repeat finding.Recommendation ? We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation and certification and supervisory approval of time charged to the federal awards. Views of Responsible Officials - The Trust will implement procedures in fiscal year 2023 requiring supervisors to review and approve time charged to federal awards in addition to the reviews performed by finance staff as part of ongoing monitoring of federal awards, including approval of time incurred during the fiscal year prior to implementation of new procedures.
2022-002 Internal Control over Compliance with Activities Allowed or Unallowed, Allowable Cost/Cost Principles ? Payroll Activities Information on the Major Federal Programs ? United States Department of Treasury Assistance Listing Number: 21.027 Assistance Listing Name: Coronavirus State and Local Fiscal Recovery Funds Passthrough Entity: State of Illinois, Department of Commerce and Economic Opportunity Program Title - Small Business Community Navigators Program Pass-through Entity Identifying Number - 21-483011 Sub-award Period - July 1, 2021 to June 30, 2022 National Endowment for the Humanities (NEH) Assistance Listing Number: 45.164 Assistance Listing Name: Promotion of the Humanities Public Programs Program Title - Telling the Full Story: Sustaining the Stewards of America?s Diverse Historic Places Award Number - ZOR-283411-21 Award Period - October 1, 2021 to September 30, 2023 Program Title - For the People by the People: Transforming National Trust Historic Sites through the Humanities Award Number - ZPP-283412-22 Award Period - October 1, 2021 to March 31, 2023 Criteria ? The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (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; (iv) Encompass both federally assisted and all other activities compensated by the non- Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During the audit, we noted that the Trust has a system of internal control by which every pay period, timesheets are submitted by each employee and approved by a supervisor. However, given the system limitations from the time-entry system, employees can only charge hours to their home department, and those employees who do not work solely on the federal program are not able to charge hours directly to the federal award through the system. Given the system limitations, program managers gathered documentation to evidence the hours and associated costs which should be charged to the federal award and recorded the corresponding personnel costs to the federal award through a journal entry; however, there was no direct evidence of review and approval of these personnel costs charged to the federal awards, other than an approval of the journal entry. While there was a lack of direct approval of hours charged to the federal program by program managers, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause ? The Trust?s system of internal control did not have procedures in place for program managers to approve the hours charged to the federal awards. Effect or Potential Effect ? Without direct approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over recording of time exists. Questioned Costs ? None. Context - This is a condition identified based upon our review of the Trust?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. Repeat finding ? This is not a repeat finding.Recommendation ? We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation and certification and supervisory approval of time charged to the federal awards. Views of Responsible Officials - The Trust will implement procedures in fiscal year 2023 requiring supervisors to review and approve time charged to federal awards in addition to the reviews performed by finance staff as part of ongoing monitoring of federal awards, including approval of time incurred during the fiscal year prior to implementation of new procedures.
2022-002 Internal Control over Compliance with Activities Allowed or Unallowed, Allowable Cost/Cost Principles ? Payroll Activities Information on the Major Federal Programs ? United States Department of Treasury Assistance Listing Number: 21.027 Assistance Listing Name: Coronavirus State and Local Fiscal Recovery Funds Passthrough Entity: State of Illinois, Department of Commerce and Economic Opportunity Program Title - Small Business Community Navigators Program Pass-through Entity Identifying Number - 21-483011 Sub-award Period - July 1, 2021 to June 30, 2022 National Endowment for the Humanities (NEH) Assistance Listing Number: 45.164 Assistance Listing Name: Promotion of the Humanities Public Programs Program Title - Telling the Full Story: Sustaining the Stewards of America?s Diverse Historic Places Award Number - ZOR-283411-21 Award Period - October 1, 2021 to September 30, 2023 Program Title - For the People by the People: Transforming National Trust Historic Sites through the Humanities Award Number - ZPP-283412-22 Award Period - October 1, 2021 to March 31, 2023 Criteria ? The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (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; (iv) Encompass both federally assisted and all other activities compensated by the non- Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During the audit, we noted that the Trust has a system of internal control by which every pay period, timesheets are submitted by each employee and approved by a supervisor. However, given the system limitations from the time-entry system, employees can only charge hours to their home department, and those employees who do not work solely on the federal program are not able to charge hours directly to the federal award through the system. Given the system limitations, program managers gathered documentation to evidence the hours and associated costs which should be charged to the federal award and recorded the corresponding personnel costs to the federal award through a journal entry; however, there was no direct evidence of review and approval of these personnel costs charged to the federal awards, other than an approval of the journal entry. While there was a lack of direct approval of hours charged to the federal program by program managers, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause ? The Trust?s system of internal control did not have procedures in place for program managers to approve the hours charged to the federal awards. Effect or Potential Effect ? Without direct approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over recording of time exists. Questioned Costs ? None. Context - This is a condition identified based upon our review of the Trust?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. Repeat finding ? This is not a repeat finding.Recommendation ? We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation and certification and supervisory approval of time charged to the federal awards. Views of Responsible Officials - The Trust will implement procedures in fiscal year 2023 requiring supervisors to review and approve time charged to federal awards in addition to the reviews performed by finance staff as part of ongoing monitoring of federal awards, including approval of time incurred during the fiscal year prior to implementation of new procedures.