FINDING 2022-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20/21, FY 21/22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context A sample of 40 vendor disbursements from the School Lunch fund was selected for testing to verify the transactions were for allowable activities and costs. There were 3 of the 40 transactions, totaling $4,129, that were paid to vendors for which the School Corporation could not provide documentation to support the costs. As such, the 3 transactions could not be verified as an allowable activity or cost of the food service program and were considered questioned costs. Due to the number and magnitude of exceptions, per auditor judgment, we concluded it would not be appropriate to examine the remaining 29 disbursements. Additionally, the School Corporation incurred costs in the amount of $49,365 paid from the School Lunch fund for a vehicle used to distribute meals to students at the Indiana Department of Education approved meal sites during the COVID-19 pandemic shutdown. The School Corporation could not provide supporting documentation that prior written approval was received from the pass-through entity. Finally, in fiscal year 2021-2022, the School Corporation paid a portion of the Assistant Superintendent of Schools salary from the School Lunch fund without supporting documentation to support the percentage paid. The Assistant Superintendent of Schools spent time on federal program and nonfederal program activities, but did not maintain documentation of time spent on each activity. The total paid to the Assistant Superintendent of Schools from the School Lunch fund without proper documentation was $29,753. The costs that were not properly documented were considered questioned costs. The lack of internal controls, availability of supporting documentation, 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 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 2 CFR 200.334 (Revised Uniform Guidance) states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.439(b) states in part: "The following rules of allowability must apply to equipment and other capital expenditures: (1) Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or pass-through entity. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and made available for audit with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $83,247 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and to comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-002 ? Allowable Costs and Allowable Activates ? Absence of Records in support of Personal Costs charged to federal programs (Material Weakness) U.S. Department of Education Elementary and Secondary School Emergency Relief Fund (Federal Assistance Listing #84.425) Federal: Federal Award Year: 2021-2022 Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and, ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; 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: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time incurred was used as a basis for allocating personnel charges to the federal grant. Cause: Current policies and procedures of the Charter School do not require documented timekeeping by employees who worked on the grant program, and therefore, there as no documentation that such time had been appropriately reviewed and approved, prior to being charged to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Questioned Costs: $14,160 Context: For our direct labor allowable costs sample, The Charter School?s management indicated that all 40 expenditure selections, totaling $14,160, were charged to the grant based on visual check ins by the operating manager onsite of the employees who conducted the related afterschool activities associated with the grant. This finding appears to be a systemic problem and that the total population which could be subject to similar questioned costs is $171,140. There was no further documentation available for our review and inspection, such as time sheets with employee or supervisor signatures, which would provide support that employees were present at the time frames paid for their services. Identified as a Repeat Finding: No. Recommendation: We recommend that the Charter School implement polices and training to staff in order to gain an understanding of the uniform guidance compliance requirements. Views of Responsible Officials: See management?s response and corrective action plan.
Finding 2022-002 ? Allowable Costs and Allowable Activates ? Absence of Records in support of Personal Costs charged to federal programs (Material Weakness) U.S. Department of Education Elementary and Secondary School Emergency Relief Fund (Federal Assistance Listing #84.425) Federal: Federal Award Year: 2021-2022 Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis; and, ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; 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: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time incurred was used as a basis for allocating personnel charges to the federal grant. Cause: Current policies and procedures of the Charter School do not require documented timekeeping by employees who worked on the grant program, and therefore, there as no documentation that such time had been appropriately reviewed and approved, prior to being charged to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Questioned Costs: $14,160 Context: For our direct labor allowable costs sample, The Charter School?s management indicated that all 40 expenditure selections, totaling $14,160, were charged to the grant based on visual check ins by the operating manager onsite of the employees who conducted the related afterschool activities associated with the grant. This finding appears to be a systemic problem and that the total population which could be subject to similar questioned costs is $171,140. There was no further documentation available for our review and inspection, such as time sheets with employee or supervisor signatures, which would provide support that employees were present at the time frames paid for their services. Identified as a Repeat Finding: No. Recommendation: We recommend that the Charter School implement polices and training to staff in order to gain an understanding of the uniform guidance compliance requirements. Views of Responsible Officials: See management?s response and corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Lunch Program Assistance Listing Number: 10.555 Federal Award Number(s) and Year(s)(or Other Identifying Numbers): Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Activities, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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)...." USDA Indirect Cost Guidance Memo SP 60-2016 "It is unallowable to bill the nonprofit school food service account (NSFSA) for indirect costs that were previously paid from the general fund unless an agreement exists to show that the district had been ?loaning? the NSFSA funds to cover the indirect costs in one or more prior years." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-003 (Continued) 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-003 (Continued) 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 Allowable Activities and Allowable Costs/Cost Principles compliance requirements. The School Corporation did not have a documented internal control over payroll claims allocation reports in place relating to the Allowable Activities and Allowable Costs/Cost Principles compliance requirements. The School Corporation did not have internal controls over indirect costs that would ensure they were properly paid. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed and Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: Known questioned costs of $74,500 were identified. Context: The School Corporation was approved for an indirect cost rate for fiscal years 2019-2020 and 2020-2021 in order to allocate indirect costs to the School Corporation?s Cafeteria fund. However, the School Corporation did not charge these indirect costs in the appropriate time frame. On June 30, 2022 the School Corporation applied the indirect costs retroactively for the child nutrition cluster fiscal year's 2019-2020 and 2020-2021 in the amounts of approximately $33,150 and $41,350, respectively from the Cafeteria Fund to the Operations Fund. For after the fact transfers, the School Corporation is required to enter into an inter-fund loan agreement and to document the Operation fund support of the School Lunch fund. The School Corporation did not have a documented internal control over payroll claims in place relating to the Allowable Activities and Allowable Costs compliance requirements. There was no documented, formal review over the supporting payroll distribution report to support the amount charged and allocated for each employee. The lack of internal controls was a systemic issue throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls for the timing of indirect costs claims and transfers. Views of Responsible Officials and Planned Corrective Actions: Management understands the finding, has prepared an initial corrective action plan and will discuss resolution with Indiana Department of Education.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Lunch Program Assistance Listing Number: 10.555 Federal Award Number(s) and Year(s)(or Other Identifying Numbers): Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Activities, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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)...." USDA Indirect Cost Guidance Memo SP 60-2016 "It is unallowable to bill the nonprofit school food service account (NSFSA) for indirect costs that were previously paid from the general fund unless an agreement exists to show that the district had been ?loaning? the NSFSA funds to cover the indirect costs in one or more prior years." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-003 (Continued) 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-003 (Continued) 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 Allowable Activities and Allowable Costs/Cost Principles compliance requirements. The School Corporation did not have a documented internal control over payroll claims allocation reports in place relating to the Allowable Activities and Allowable Costs/Cost Principles compliance requirements. The School Corporation did not have internal controls over indirect costs that would ensure they were properly paid. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed and Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: Known questioned costs of $74,500 were identified. Context: The School Corporation was approved for an indirect cost rate for fiscal years 2019-2020 and 2020-2021 in order to allocate indirect costs to the School Corporation?s Cafeteria fund. However, the School Corporation did not charge these indirect costs in the appropriate time frame. On June 30, 2022 the School Corporation applied the indirect costs retroactively for the child nutrition cluster fiscal year's 2019-2020 and 2020-2021 in the amounts of approximately $33,150 and $41,350, respectively from the Cafeteria Fund to the Operations Fund. For after the fact transfers, the School Corporation is required to enter into an inter-fund loan agreement and to document the Operation fund support of the School Lunch fund. The School Corporation did not have a documented internal control over payroll claims in place relating to the Allowable Activities and Allowable Costs compliance requirements. There was no documented, formal review over the supporting payroll distribution report to support the amount charged and allocated for each employee. The lack of internal controls was a systemic issue throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls for the timing of indirect costs claims and transfers. Views of Responsible Officials and Planned Corrective Actions: Management understands the finding, has prepared an initial corrective action plan and will discuss resolution with Indiana Department of Education.
Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A ? Direct Award Program Name: Head Start Cluster Assistance Listing Number:93.600 Award Numbers: 05CH01205802, 05HE00139001C6, 05HP00044002 Category of Finding: Allowable Costs/Cost Principles Criteria: Reports reflecting the distribution of activity of each employee much be maintained for all staff members whose compensation is charged, in whole or in part, directly to awards in accordance with the Uniform Guidance CFR Section 200.430 ? Compensation ? personal Services. Charges to Federal awards must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and incorporated into the official records of the Center. These records much also support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one program or activity. Condition/Context: The Center uses the Time Recording module of its Human Resources Information System (HRIS) to allocate gross wages for all employees. Management asserts that the HRIS is populated with labor allocations reflect of program benefit for each employee and four times during each fiscal year, Management re-evaluates labor allocation for potential changes. During fiscal year 2022, spreadsheets were used, outside of HRIS data tables, for tracking labor allocations. The use of spreadsheets did not provide for a consistent documented procedure that could be effectively tested to demonstrate that a system of internal controls was in place to provide reasonable assurance changes to allocations were supported, accurate and allowable. Cause: The Center?s significant growth, along with staff challenges during COVID recovery, and the transition to a new HIRS resulted in extensive use of spreadsheets for the tracking of labor allocations and changes to allocations during the year and internal control processes that were not fully developed to address these changes. Effect: The Center?s use of spreadsheets for labor allocations did not provide a documented system of internal control that could be used to test changes to allocations made during the year. Questioned Costs: None. Repeat Finding: No Recommendation: Management should review the written fiscal policy and procedures as it relates to the allocation of salaries and ensure that what is documented is reflective of internal controls and processes in place to provide reasonable assurance that the charges are accurate, allowable and properly allocated and incorporated into the official records of the Center. We recommend that the HIRS Time Recording module be used to maintain records of daily entries for exempt staff. The reporting capability of the HIRS should be the only source used to generate the calculation of wage allocations entered into the general ledgers. The allocation reviews performed throughout the year of program benefit assigned to each position should be documented and approved such that there is the ability to track determinations and related support. We noted that Management has taken several steps to improve this process by the end of the fiscal year. Management?s response: Management agrees with this finding. Please see corrective action plan.
A. Finding on Internal Control over Compliance Finding Reference: 2022-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, were required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal controls over the employee?s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2021-001. Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.
A. Finding on Internal Control over Compliance Finding Reference: 2022-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, were required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal controls over the employee?s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2021-001. Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.