Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Questioned Cost and Noncompliance 2 CFR ? 400.1 gives regulatory effect for the U.S. Department of Agriculture to the Office of Management and Budget guidance, as supplemented by this part. This part adopts in the OMB guidance in subparts A through F of 2 CFR part 200. 2 CFR ? 200.430(a) provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; 2. Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 15, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective: ? Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category. ? Time and effort documentation is used when an employee's compensation is funded by more than one federal grant. ? The substitute system of collecting time and effort is used when an employee?s compensation is funded by more than one grant. Due to a deficiency in internal policies and procedures over compliance, the food service director, who is partially paid by contract from the Child Nutrition Cluster funds, did not obtain semi-annual certifications for payroll and benefit expenditures which resulted in Child Nutrition Cluster actual expenditures of $25,794 not being supported with semi-annual certifications or time sheets and will be considered a questioned cost. Based on the above guidance, the employee should have completed semi-annual certifications as their compensation was funded by a single Federal grant. The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete semi-annual certifications for single source funded personnel and time and effort documentation for payroll charges for split funded personnel. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation
Finding 2022-008: Unallowable cost?salary certification and personnel activity reports Repeat Finding Yes (2021-009) Federal Program Title: U.S. Department of Justice Passed through Illinois Criminal Justice Information Authority 16.575; Crime Victim Assistance Award Year Award# 219040: March 23, 2021 ? May 31, 2022 Award# 220040: June 1, 2022 ? November 30, 2023 Criteria: Article 23 of the Illinois Criminal Justice Information Authority grant agreement states that personnel who spend 100% of their time on the funded program must certify on a semi-annual basis. Additionally, Article 23 of the Illinois Criminal Justice Information Authority grant agreement states that personnel who spend less than 100% of their time on the funded program must maintain Personnel Activity Reports (PAR) that accurately reflects the time the employee spends performing the program and any other duties. 2 CFR 200.430 requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: There were two employees designated as spending 100% of their time on the grant who did not complete their 100% Time Certificates. There were also seven employees allocated at less than 100% to the grant who did not complete any Personnel Activity Reports during the fiscal year. Of the Personnel Activity Reports that we were able to review, all were completed significantly after the fact rather than during the grant period tested. Cause: Due to turnover in program staffing, program oversight was not performed timely. Effect: Unallowable costs were submitted for reimbursement causing UCAN to be in noncompliance with Article 23 of the grant agreement. Questioned costs: We are unable to determine if the two employees allocated 100% to the grant actually worked 100% of their time on the funded program. These five selections resulted in $7,832 of questioned cost, based on the portion of the salary we tested. For the seven employees allocated at less than 100% to the grant, we are unable to determine the amount of time that the employees worked on the funded program, therefore 11 selections resulted in questioned costs of $13,395, representing the amount tested. In total, the questioned costs are $21,227. Context: Out of 12 employees tested who were allocated 100% to the grant, there were two employees where a self-certification was not completed during the year. This represented 2 out of 42 transactions tested. Out of 10 employees tested who were allocated to the grant at less than 100%, there were seven employees where a Personnel Activity Report was not completed during the year. Of the 18 transactions tested where personnel charged less than 100% to the grant, 11 of the Personnel Activity Reports were not prepared. Recommendation: We recommend that management improve internal controls for identifying and communicating compliance requirements per the grant agreement. Further, we recommend that management implement an internal control activity to verify that all employees charging 100% of their time to the funded program complete a self-certification on a semi-annual basis and that all employees charging less than 100% of their time to the funded program complete a Personnel Activity Report. All Personnel Activity Reports should be completed and reviewed timely. Views of responsible officials: Management agrees with this finding. Please see corrective action plan attached.
Reference Number: 2022-012 Prior Year Finding: 2021-010 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Public Health Federal Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: NU50CK000497 (8/1/2019 ? 7/31/2024) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Twelve of sixty time and effort certifications selected for testing were not certified and obtained until after the documentation was requested for audit. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division of Public Health Laboratory (DPHL) has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. ELC Grant Managers use various tools to monitor personnel funding: Organizational charts, grant budget requests, wage workups, and funding transfer notifications (FTNs) for budget positions associated with ELC. Our process has been overhauled and time and effort attestation and certification forms are being collected for all grants managed by the DPH Laboratory every 6 months. In addition, ELC Grant Managers at DPHL developed a new standard operating procedure (SOP), worked with DMS to be trained on the requirements, and work towards a new internal standard.
Reference Number: 2022-012 Prior Year Finding: 2021-010 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Public Health Federal Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: NU50CK000497 (8/1/2019 ? 7/31/2024) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Twelve of sixty time and effort certifications selected for testing were not certified and obtained until after the documentation was requested for audit. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division of Public Health Laboratory (DPHL) has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. ELC Grant Managers use various tools to monitor personnel funding: Organizational charts, grant budget requests, wage workups, and funding transfer notifications (FTNs) for budget positions associated with ELC. Our process has been overhauled and time and effort attestation and certification forms are being collected for all grants managed by the DPH Laboratory every 6 months. In addition, ELC Grant Managers at DPHL developed a new standard operating procedure (SOP), worked with DMS to be trained on the requirements, and work towards a new internal standard.
Reference Number: 2022-015 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Social Services Federal Program: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Award Number and Year: 20210DETANF (10/1/2019 ? 9/30/2025), 2222DETANF (10/1/2021 ? 9/30/2026) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (vi) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Be incorporated into the official records of the non-Federal entity; (viii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (ix) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (x) Comply with the established accounting policies and practices of the non-Federal entity; (viii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Context: For five of forty payroll transactions selected for testing, documentation could not be provided to support that employee time and effort charged to the program had been certified and approved. Questioned costs: Questioned costs of $8,231 represent the amount of unsupported payroll expenditures charged to the grant. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division of Social Services (DSS) will review and strengthen its internal controls in regard to time and effort reporting to ensure it can substantiate all reimbursements from federal programs. This review will include other DHSS divisions and state agencies that receive TANF funds for time and effort. Exceptions were due to position changes, retirement and untimely submission of supporting documents. Issues identified by the audit have been corrected.
Reference Number: 2022-027 Prior Year Finding: 2021-025 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (xi) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (xii) Be incorporated into the official records of the non-Federal entity; (xiii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (xiv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (xv) Comply with the established accounting policies and practices of the non-Federal entity; (ix) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Eight payroll transactions were selected for testing and the following exceptions were noted: ? Four of eight time and effort certifications were not certified and obtained until after the documentation was requested for audit. ? No time and effort certifications were provided for three of eight transactions. Questioned costs: Questioned costs of $2,355 represent the amount of unsupported payroll expenditures charged to the grant. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division will improve the current process through enhanced internal controls and updated training for staff to ensure a clear understanding of the requirements for certification and reporting of time and effort when charged to a federal grant.
Reference Number: 2022-027 Prior Year Finding: 2021-025 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (xi) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (xii) Be incorporated into the official records of the non-Federal entity; (xiii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (xiv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (xv) Comply with the established accounting policies and practices of the non-Federal entity; (ix) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Eight payroll transactions were selected for testing and the following exceptions were noted: ? Four of eight time and effort certifications were not certified and obtained until after the documentation was requested for audit. ? No time and effort certifications were provided for three of eight transactions. Questioned costs: Questioned costs of $2,355 represent the amount of unsupported payroll expenditures charged to the grant. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division will improve the current process through enhanced internal controls and updated training for staff to ensure a clear understanding of the requirements for certification and reporting of time and effort when charged to a federal grant.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: Passed through the State of Maine Agency of Education ALN - 84.425 - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1) Condition: During audit procedures, it was identified that the School Department did not have documented payrates on file for some employees. Cause: The School Department does not require payrate documentation for all employees. Effect: Employees may not be paid the correct amount. This could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds. Identification of Questioned Costs: None identified. Context: Out of a sample of 19 payrolls, it was determined that 5 employees did not have documented payrates on file. This is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that payroll files are complete and all employees have documented payrates. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: Passed through the State of Maine Agency of Education ALN - 84.425 - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1) Condition: During audit procedures, it was identified that the School Department did not have documented payrates on file for some employees. Cause: The School Department does not require payrate documentation for all employees. Effect: Employees may not be paid the correct amount. This could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds. Identification of Questioned Costs: None identified. Context: Out of a sample of 19 payrolls, it was determined that 5 employees did not have documented payrates on file. This is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that payroll files are complete and all employees have documented payrates. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: Passed through the State of Maine Agency of Education ALN - 84.425 - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1) Condition: During audit procedures, it was identified that the School Department did not have documented payrates on file for some employees. Cause: The School Department does not require payrate documentation for all employees. Effect: Employees may not be paid the correct amount. This could result in unallowable expenses being charged and subsequently improperly reimbursed by federal funds. Identification of Questioned Costs: None identified. Context: Out of a sample of 19 payrolls, it was determined that 5 employees did not have documented payrates on file. This is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that payroll files are complete and all employees have documented payrates. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the School Department.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
2022-001 Improve Time and Effort Documentation (Material Weakness) Federal Agency: Department of Education Cluster/Program: Special Education Cluster and Education Stabilization Fund AL Number(s): 84.027/84.173, 84.425 Award Year: 2021 and 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance and Internal Control over Compliance - Material Weakness Criteria or Specific Requirement Federal grant recipients are required to maintain federally compliant documentation to support time and effort of employees working solely or partially on federal grants. These records must be maintained in accordance with federal cost principles (Uniform Guidance, 2 CFR Part 200.430), and must, in some documented fashion, provide evidence that the time charged to federal programs represents the time actually spent on that grant function by the employee. For employees who work partially on grant activities, time logs should be prepared and must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. For employees who work solely on grant activities, semi-annual certifications can be prepared and also must be signed by either the employee or a supervisor knowledgeable of the work performed by the employee. Management of the School Department is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The School Department did not have adequate documentation to support the time and effort of employees who charged time to grant activities. The documentation did not clearly state the distribution of the employee?s time spent on grant activities. Cause The School Department does not have adequate controls in place over time and effort procedures. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Known and likely questioned costs reported are all payroll and related costs charged, as follows: Questioned Costs Known questioned costs are reported equal to $1,241,221, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 84.027/84.173 Special Education Cluster $596,331 84.425 Education Stabilization Fund $644,890 Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2021-002. Recommendation The School Department should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Documentation should be retained to support time and effort of all employees who charge time to grant activities in accordance with applicable federal guidelines. Views of Responsible Official Management?s views and corrective action plan is included in a separate corrective action plan.
Finding 2022-003: Time Tracking and Reporting Information on the Federal Program: 93.368 Criteria: CFR 200.430 indicates that the allocation of salaries for employees must be consistently applied to both Federal and Non-Federal activities. Condition: We noted that time tracking was only required for employees charging time to federal awards. Additionally, the time tracking only included time spent by the employee on Federal activities, and not non-Federal activities. Timesheets should be required for all staff and should include time spent on both non-Federal and Federal activities in order to be in compliance with the Uniform Guidance. Additionally, we noted that timesheets lacked evidence of employee attestation. All timesheets should include employee signature to verify accuracy of time reported. Cause: Policies in place at the Foundation over time tracking only require that time spent on the Federal-activities be tracked. Policies also do not require employee signature on the timesheets prior to submission. Effect: It is possible that time charged to the Federal activities is not accurate as the allocation is not based on true time spent on activities as a whole, including both Federal and non-Federal. Questioned Costs: Unknown Context: Our audit procedures consisted of testwork completed on individual employee timesheets for certain pay periods. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: 2021-002. Recommendation: Timesheets should be required for all staff and should also include time spent on both Federal and non-Federal activities in order to be in compliance with Uniform Guidance Cost Principals. Additionally, all timesheets should include employee signature to verify accuracy of time reported.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other MattersCondition and Context An effective system of internal control was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, an employee had duties related to the operation of the food service program and other nonfederal duties. The employee's wages were paid from both grant and nongrant funds. However, the employee did not maintain documentation of time spent on each activity. Therefore, all salary costs charged to the Child Nutrition Cluster during the time the employee performed both roles were considered questioned costs. Total questioned costs were $36,424. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430(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 . . . (iv) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal control, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $36,424 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Grant Number & Year: S010A190027, FFY 2020; S010A200027, FFY 2021 Federal Grantor Agency: U.S. Department of Education Criteria: Per 2 CFR ? 3474.1 (January 1, 2022), the U.S. Department of Education adopted the OMB Uniform Guidance in 2 CFR part 200, except for 2 CFR ? 200.102(a) and 200.207(a). Per 2 CFR ? 200.403 (January 1, 2022), allowable costs must be necessary, reasonable, and adequately documented. 2 CFR ? 200.430(i)(1) (January 1, 2022) states, in relevant part, the following: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . . ; (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity . . . . ; and * * * * (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. Enclosure A of the ?Letter to Chief State School Officers on Granting Administrative Flexibility for Better Measures of Success? (September 7, 2012) provides guidelines for local educational agencies (LEAs), using a substitute system for time-and-effort reporting. Enclosure A states, in relevant part, the following: (3) Employee schedules must: a. Indicate the specific activity or cost objective that the employee worked on for each segment of the employee?s schedule; b. Account for the total hours for which each employee is compensated during the period reflected on the employee?s schedule; and c. Be certified at least semiannually and signed by the employee and a supervisory official having firsthand knowledge of the work performed by the employee. 2 CFR ? 200.332 (January 1, 2022) states, in relevant part, the following: All pass-through entities must: * * * * (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: * * * * (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient . . . . A good internal control plan requires that adequate documentation be maintained to support amounts claimed by and paid to subrecipients. Good internal control also requires procedures to follow up with subrecipients to ensure they are correcting deficiencies and in compliance with applicable regulations. Condition: The Agency lacked procedures to ensure that subrecipients documented their use of Federal awards appropriately. Repeat Finding: No Questioned Costs: $145,101 known (S010A190027, $8,041; S010A200027, $137,060) Statistical Sample: No Context: We randomly selected 25 subrecipient payments and also chose the largest subrecipient payment for testing. We noted the following: ? Several employees? salaries and benefits were included in the reimbursement requests; however, the Agency did not require subrecipients to submit documentation for these expenditures, other than reports from their accountings systems, at the time of reimbursement. We provided the Agency with an opportunity to request documentation from its subrecipients to support that their salaries and benefits expenses were allowable and in accordance with Federal cost principles; however, two of the subrecipients did not provide adequate support to show that their salaries and benefits were allocable to the grant, resulting in $8,041 sample questioned costs and $137,060 non-sample questioned costs. ? The Agency?s procedure is to perform fiscal reviews of each subrecipient at least once every three years. We reviewed the most recent fiscal reviews for the same 26 subrecipients selected for testing above. For five of these reviews, the Agency noted that the subrecipient did not maintain adequate documentation for salaries and benefits. When we inquired with the Agency regarding what had been done to follow up on its findings, the Agency replied that the findings did not require follow-up. Payment errors noted for the sample tested were $8,041. The total sample tested was $1,494,006. Subrecipient aid payments for the fiscal year ended June 30, 2022, totaled $91,043,602. The sample population was $84,396,850 (total population $91,043,602 less $6,646,752 to largest subrecipient that was separately determined to be allowable). Based on the sample tested, the case error rate was 8% (2/25). The dollar error rate for the sample was 0.54% ($8,041/$1,494,006), which estimates the potential dollars at risk for fiscal year 2022 to be $455,753 (dollar rate multiplied by the population). Cause: Inadequate procedures. Effect: Without adequate supporting documentation and monitoring procedures, there is an increased risk that Federal awards could be used for unallowable costs. Recommendation: We recommend the Agency improve procedures to monitor subrecipients, including reviewing detailed supporting documentation for payroll expenses and following up with subrecipients to ensure that they correct errors noted. Management Response: The Department agrees the two subrecipients sampled did not complete one time and effort certification semi-annually (rather completed annually instead) or with all language suggested in the guidelines from the U.S. Department of Education. However, the Department disagrees with the reimbursement being questioned costs as the time and effort certifications demonstrated adequate documentation to support the employees? activities were allowable for the Title I grant. In the absence of this information, the Department submitted affidavits from the two LEA?s supervisory staff with personal knowledge of the work performed consistent with the U.S. Department of Education?s audit resolutions practices; whereas the APA does not consider documentation after the fact to be adequate to eliminate the finding. The findings noted in the subrecipient fiscal monitoring exit letters were identified for technical assistance purposes only and not considered to have met a level of materiality that required a corrective action plan. Corrective action plans are clearly noted in subrecipient fiscal monitoring exit letters when issued and proper follow-up action is taken when this occurs. Technical assistance was provided to each of the subrecipients at the time of the monitoring review as well as to all subrecipients periodically throughout the year. APA Response: Per the Uniform Guidance, questioned costs include expenditures that lack adequate supporting documentation at the time of the audit. 2 CFR ? 200.430(i)(1) (January 1, 2022), as referenced in the report comment, says that such documentation must ?accurately reflect the work performed? and be ?supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.? Affidavits dated February 27, 2023, some 18 months after the salary and benefit expenses occurred, cannot possibly satisfy either of these requirements and are, therefore, not acceptable. As the documentation provided did not meet the minimum requirements set forth in Uniform Guidance and guidance issued by the U.S. Department of Education, the expenditures at issue must be considered questioned costs. Moreover, the Uniform Guidance requires the Agency, as the pass-through entity, to ensure that the subrecipient takes timely and appropriate action to address deficiencies identified not only during audits but also from the Agency?s own reviews. The Agency has noted issues similar to those addressed by the APA ? namely, that the subrecipients have lacked adequate supporting documentation for salary and benefit expenses. The Agency performs subrecipient fiscal monitoring for most subrecipients only every third year. Thus, effective follow-up procedures, as required by 2 CFR ? 200.332 (January 1, 2022), are needed to ensure that subrecipients implement the technical assistance provided by the Agency.
Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Grant Number & Year: NE-2019-013-00, FFY 2017 Federal Grantor Agency: U.S. Department of Transportation Criteria: Per 2 CFR ? 1201.1 (January 1, 2022), the U.S. Department of Transportation adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at Title 2 CFR part 200. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. A good internal control plan requires procedures to be in place to ensure compliance with Federal and State requirements. 2 CFR ? 200.332(d) (January 1, 2022) requires the pass-through entity to do the following: Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. 2 CFR ? 200.430(i)(1) (January 1, 2022) states the following, in relevant part: 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; * * * * (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards . . . [.] Per 2 CFR ? 200.405(a) (January 1, 2022), ?A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Condition: The Agency lacked adequate documentation to support that payments were for allowable activities and in accordance with Federal cost principles. A similar finding was noted in the prior audit. Repeat Finding: 2021-065 Questioned Costs: $64,704 known Statistical Sample: No Context: We tested 25 payments to 22 subrecipients and three vendors. The Agency performed financial desk reviews for subrecipients; however, the reviews tested were not adequate. When desk reviews were not adequate, we provided the Agency with the opportunity to obtain additional support from the subrecipient; however, adequate support was not obtained. We noted the following: ? For nine subrecipients tested, documentation was not adequate to support that personnel charges were allowable and in accordance with Federal cost principles. The Agency did not have timesheets, time certifications, or other payroll documentation on file for all reimbursement requests. In some cases, payroll documentation was on file, but there was not adequate support to verify that the correct amount was charged to the program, as timesheets were not sufficient to identify time allocated to the program when the employee did not work entirely on the Federal program. In addition, for some subrecipients there was not sufficient documentation to support the benefits reimbursed. ? For one subrecipient tested, fuel costs and maintenance expenses were not adequately supported. The expenses were not supported by invoices. ? For seven subrecipients tested, capital and nonoperating costs were not adequately supported. The Agency did not obtain documentation to support the percentage of nonoperating expenditures allocated to the program. Subrecipients may share building space with other city or county offices and, therefore, may be charged a portion of the rent and utilities. While this is allowable, the Agency must obtain documentation to support that the percent allocated to the transit program is reasonable; however, such supporting documentation was not available. We also noted that one subrecipient was improperly reimbursed for sales taxes. The sample population totaled $15,537,764, which included $12,810,135 paid to 60 subrecipients and $2,727,629 vendor payments. Federal payment errors noted in the sample totaled $24,600. The total Federal sample tested was $353,695. Based on the sample tested, the dollar error rate was 6.96% ($24,600/$353,695), which estimates the potential dollars at risk for fiscal year 2022 to be $1,081,428 (dollar error rate multiplied by population). North Fork Area Transit During the course of our audit, we became aware of potential fraud related to the North Fork Area Transit (NFAT), a subrecipient of the Agency. On December 15, 2022, the Director of NFAT was suspended. A warrant was issued for his arrest the next day, alleging theft of up to $1 million between April and December 2022. From April 1, 2022, through June 30, 2022, the Program reimbursed NFAT a total of $582,587. As a result, we selected the April 2022 reimbursement paid to NFAT in June 2022, totaling $101,519, for additional testing. During that testing we identified $40,104 in questioned costs due to the following: ? For all four non-operating personnel (director and managers), documentation was inadequate to support that personnel charges were allowable and in accordance with Federal cost principles, as the timesheets identified only times in and out and did not specify what work the nonoperating employee was performing for the Federal grant. Questioned costs due to the lack of support for nonoperating personnel totaled $24,104. ? A $20,000 payment for vehicle insurance was reported; however, there was no documentation to support how the amount was determined or why it was reasonable. Furthermore, the $20,000 paid was inconsistent with past vehicle insurance payments. We observed a check in March 2022 for $600 with the description that it was for March bus insurance, and previous testing identified $600 bus insurance checks in August 2020 and August 2021. As a result, we question the Federal share of $16,000. ? We also noted inconsistencies in supporting documentation for operating personnel (drivers and dispatchers). Variances were noted between timesheet hours and the payroll register. Due to the NFAT concerns, the APA has now commenced a thorough review of this entire matter, which will be reported separately at a later date. Cause: Procedures were not adequate to ensure that costs were in accordance with Federal requirements. Effect: Increased risk for errors or misuse of funds. Recommendation: We recommend the Agency strengthen subrecipient monitoring procedures. We further recommend the Agency improve procedures to ensure expenditures are allowable and in accordance with Federal regulations. Management Response: The NDOT Local Assistance Division has increased transit staff by 1.5 FTEs for a total of 3.5 FTEs dedicated to reviewing monthly invoices. NDOT continues to engage and educate transit recipients. In late 2022, the North Fork Area Transit (NFAT) Board began an internal review process which revealed an inappropriate use of funds and authorities were notified. In December 2022, the NFAT Board engaged NDOT and requested assistance from the Mobility Management Team following the allegation. The Mobility Management Team is assisting the NFAT Board in managing operations, review of existing reporting and financial policies, and review and update of step-by-step checks and balances process. NDOT is financially supporting the Mobility Management Team in an effort to support and resume services at NFAT.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Time records provided to support salaries and wages charged to the school lunch revolving fund were not approved by supervisory personnel. Cause: The District did not assign the approval of federal payroll documentation to any employee. Effect: Lack of supervisory approval of time records may lead to errors in charging salaries and wages to the federal program. Questioned Costs: None Recommendation: The District should implement procedures to have supervisory personnel approve time records for all employees? whose salaries and wages are charged to the school lunch revolving fund. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Time records provided to support salaries and wages charged to the school lunch revolving fund were not approved by supervisory personnel. Cause: The District did not assign the approval of federal payroll documentation to any employee. Effect: Lack of supervisory approval of time records may lead to errors in charging salaries and wages to the federal program. Questioned Costs: None Recommendation: The District should implement procedures to have supervisory personnel approve time records for all employees? whose salaries and wages are charged to the school lunch revolving fund. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Time records provided to support salaries and wages charged to the school lunch revolving fund were not approved by supervisory personnel. Cause: The District did not assign the approval of federal payroll documentation to any employee. Effect: Lack of supervisory approval of time records may lead to errors in charging salaries and wages to the federal program. Questioned Costs: None Recommendation: The District should implement procedures to have supervisory personnel approve time records for all employees? whose salaries and wages are charged to the school lunch revolving fund. Views of Responsible Official: Management agrees with the finding.
2022-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Child Nutrition Cluster ? CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Time records provided to support salaries and wages charged to the school lunch revolving fund were not approved by supervisory personnel. Cause: The District did not assign the approval of federal payroll documentation to any employee. Effect: Lack of supervisory approval of time records may lead to errors in charging salaries and wages to the federal program. Questioned Costs: None Recommendation: The District should implement procedures to have supervisory personnel approve time records for all employees? whose salaries and wages are charged to the school lunch revolving fund. Views of Responsible Official: Management agrees with the finding.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
2022-001: Procurement Policy and Procedures Condition: Several purchases were made in excess of the micro purchase threshold ($10,000). The Organization could not provide documentation to show they obtained quotes, or the reason quotes were not obtained, or if they gave preference to minority or women-owned businesses. Cause: The Organization has not established a written procurement policy. Criteria: The Code of Federal Regulations requires that entities receiving federal funding have a written procurement policy. The required elements of the procurement policy are detailed out in the Electronic Code of Federal Regulations (eCFR) under Title 2, Subtitle A, Part 200, Subpart D, 200.317 thru 200.327. Several other areas require written policies: financial management (200.302), federal payment (200.305), compensation-personal services (200.430), compensation-fringe benefits (200.431), relocation costs of employees (200.464), and travel costs (200.475). Effect: Lack of such policies increases the risk of purchasing items at higher prices than may have been necessary, increases the risk of limiting competition, and increases the risk of waste and abuse. Perspective Information: The need for a procurement policy was brought to the CEO's attention in the fall of 2021. The CEO does believe the spirit of the procurement requirements were met. Recommendations: We recommend quotes are obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained or the reasons why bids or quotes were not obtained. We also recommend a procurement policy is established as soon as possible and an individual is assigned to monitor the implementation of the policy. Views of Responsible Officials and Planned Corrective Actions: The Club agrees with this finding. Their intent is to create and implement a procurement policy that complies with the Code of Federal Regulations as soon as possible and add the proper documentation for purchases exceeding the micro purchase threshold beginning with fiscal year 2023. See Corrective Action Plan.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: We noted the University?s time and effort is documented; however, for salaried employees, the certification of actual time and effort is not timely. Internal controls did not detect these instances of noncompliance. Questioned costs: None Context: We noted the University?s time and effort is estimated at the start of each fiscal year in the initial time and effort budget. Then, at the end of the year, a certification of actual time and effort is performed. For 3 of the 60 tested, the certification of time and effort occurred more than 365 days after the selected pay date. Cause: The University stated there was a decrease in staff due to COVID-19 and furloughs that prevented implementation of bi-annual time and effort certification for salaried employees. Effect: The University?s system of internal control does not provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it is not in compliance with the standard for documentation of personnel expenses. In addition, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards. Repeat finding: Yes Recommendation: We recommend that the University increase the time and effort certification process to be more timely. View of responsible official: The University agrees with the finding.