C. Findings and Questioned Costs—Major Federal Award Programs Finding 2022‐002: Inaccurate Staff Timesheet Support Federal Grantor: US Department of Health and Human Services Passed Through: Public Health Institute Community Health Councils, Inc. and County of Los Angeles Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases and Ending the HIV Epidemic: A Plan for America Assistance Listing Number: 93.323 and 93.686 Grant Number: AR02042, 21‐DPH‐CHW‐13, and PH‐004055 Significant Deficiency over Compliance: Activities Allowed and Unallowed Criteria: Under OMB Super‐Circular 2 CFR Part 200.430.(i)(1), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Furthermore, the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurately, allowable and properly allocated, and reasonably reflect the total activity for which the employee is compensated, etc. Condition: From the contract billings for the year ended June 30, 2022, we selected four months to examine documentation for all payroll expenditures billed to federal reimbursement contracts to test for compliance with timesheet recording requirements. We determined a few instances whereby employee timesheets did not reconcile to the amounts billed to the federal contracts. The billings related to these instances were subsequently corrected by management. Cause: Employees have a lack of clarity and an information gap when being transitioned between contracts resulting in inaccurately completed timesheets. Effect or Potential Effect: When contract changes occur, timesheet references to contracts can become incorrect, resulting in related expenses being improperly recorded and billed. Questioned Costs: None Recommendation: We recommend that at each monthly staff meeting a discussion occur regarding contracts that are ending and beginning in the next month. Instructions should be made to applicable employees as to the proper charging of hours to those contracts. Views of responsible officials and planned corrective actions: The Foundation agrees with the finding; please refer to corrective action plan beginning on page 28.
Finding Number: 2022-002Repeat Finding: NoType of Finding: Significant DeficiencyDescription: Internal Control over Payroll ExpendituresCondition: Out of a sample of 20 payroll transactions there were 2 employees that were not paid at the salary or rate noted on the authorized payroll/status change notice.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: A lack of updating the payroll system to reflect the actual hourly pay rate or salary that agrees to the authorized payroll/status change notice.Effect: Without ensuring the proper pay rate or salary is entered in the payroll system, it is possible that employees could be compensated the incorrect amounts, and if paid more than the authorized rate or salary, grants could be overcharged, resulting in unallowable costs.Recommendation: We recommend that a member of the payroll department or fiscal team review each employee?s payroll/status change notice and compare to what is in the payroll system to ensure they agree.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2022-002: Represents a significant deficiency in internal control over compliance with Tallatoona Community Action Partnership, Inc.?s major federal programs.Repeat Finding: NoType of Finding: Material WeaknessDescription: Internal Control over Payroll ExpendituresMajor Programs: AL#93.569 ? Community Services Block Grant (Passed Through the Georgia Department of Human Services) and AL#93.600 ? Head Start Cluster (Direct)Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost PrinciplesAwards effected:CSBG 42700-040-0000096839 and CSBG 42700-040-0000103931COVID-19 CSBG 42700-040-0000103959 and COVID-19 CSBG 42700-040-0000095979Head Start FY-21 04CH010523-04-01 and Head Start FY-22 04CH010523-05-02COVID-19 Head Start ? CARES - FY21-FY23 04HE000247-01-01COVID-19 Head Start ? ARPA ? FY21-FY 23 04HE000247-01-01Early Head Start CCP FY 21 04HP000305-02-01 and Early Head Start CCP FY 22 04HP000305-03-00COVID-19 Early Head Start CCP CARES ? FY 21-FY 23 04HE000247-01-01COVID-19 Early Head Start CCP ARPA ? FY 21-FY 23 04HE000247-01-01View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Finding Number: 2022-002Repeat Finding: NoType of Finding: Significant DeficiencyDescription: Internal Control over Payroll ExpendituresCondition: Out of a sample of 20 payroll transactions there were 2 employees that were not paid at the salary or rate noted on the authorized payroll/status change notice.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: A lack of updating the payroll system to reflect the actual hourly pay rate or salary that agrees to the authorized payroll/status change notice.Effect: Without ensuring the proper pay rate or salary is entered in the payroll system, it is possible that employees could be compensated the incorrect amounts, and if paid more than the authorized rate or salary, grants could be overcharged, resulting in unallowable costs.Recommendation: We recommend that a member of the payroll department or fiscal team review each employee?s payroll/status change notice and compare to what is in the payroll system to ensure they agree.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2022-002: Represents a significant deficiency in internal control over compliance with Tallatoona Community Action Partnership, Inc.?s major federal programs.Repeat Finding: NoType of Finding: Material WeaknessDescription: Internal Control over Payroll ExpendituresMajor Programs: AL#93.569 ? Community Services Block Grant (Passed Through the Georgia Department of Human Services) and AL#93.600 ? Head Start Cluster (Direct)Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost PrinciplesAwards effected:CSBG 42700-040-0000096839 and CSBG 42700-040-0000103931COVID-19 CSBG 42700-040-0000103959 and COVID-19 CSBG 42700-040-0000095979Head Start FY-21 04CH010523-04-01 and Head Start FY-22 04CH010523-05-02COVID-19 Head Start ? CARES - FY21-FY23 04HE000247-01-01COVID-19 Head Start ? ARPA ? FY21-FY 23 04HE000247-01-01Early Head Start CCP FY 21 04HP000305-02-01 and Early Head Start CCP FY 22 04HP000305-03-00COVID-19 Early Head Start CCP CARES ? FY 21-FY 23 04HE000247-01-01COVID-19 Early Head Start CCP ARPA ? FY 21-FY 23 04HE000247-01-01View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Finding Number: 2022-002Repeat Finding: NoType of Finding: Significant DeficiencyDescription: Internal Control over Payroll ExpendituresCondition: Out of a sample of 20 payroll transactions there were 2 employees that were not paid at the salary or rate noted on the authorized payroll/status change notice.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: A lack of updating the payroll system to reflect the actual hourly pay rate or salary that agrees to the authorized payroll/status change notice.Effect: Without ensuring the proper pay rate or salary is entered in the payroll system, it is possible that employees could be compensated the incorrect amounts, and if paid more than the authorized rate or salary, grants could be overcharged, resulting in unallowable costs.Recommendation: We recommend that a member of the payroll department or fiscal team review each employee?s payroll/status change notice and compare to what is in the payroll system to ensure they agree.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2022-002: Represents a significant deficiency in internal control over compliance with Tallatoona Community Action Partnership, Inc.?s major federal programs.Repeat Finding: NoType of Finding: Material WeaknessDescription: Internal Control over Payroll ExpendituresMajor Programs: AL#93.569 ? Community Services Block Grant (Passed Through the Georgia Department of Human Services) and AL#93.600 ? Head Start Cluster (Direct)Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost PrinciplesAwards effected:CSBG 42700-040-0000096839 and CSBG 42700-040-0000103931COVID-19 CSBG 42700-040-0000103959 and COVID-19 CSBG 42700-040-0000095979Head Start FY-21 04CH010523-04-01 and Head Start FY-22 04CH010523-05-02COVID-19 Head Start ? CARES - FY21-FY23 04HE000247-01-01COVID-19 Head Start ? ARPA ? FY21-FY 23 04HE000247-01-01Early Head Start CCP FY 21 04HP000305-02-01 and Early Head Start CCP FY 22 04HP000305-03-00COVID-19 Early Head Start CCP CARES ? FY 21-FY 23 04HE000247-01-01COVID-19 Early Head Start CCP ARPA ? FY 21-FY 23 04HE000247-01-01View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Finding Number: 2022-002Repeat Finding: NoType of Finding: Significant DeficiencyDescription: Internal Control over Payroll ExpendituresCondition: Out of a sample of 20 payroll transactions there were 2 employees that were not paid at the salary or rate noted on the authorized payroll/status change notice.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: A lack of updating the payroll system to reflect the actual hourly pay rate or salary that agrees to the authorized payroll/status change notice.Effect: Without ensuring the proper pay rate or salary is entered in the payroll system, it is possible that employees could be compensated the incorrect amounts, and if paid more than the authorized rate or salary, grants could be overcharged, resulting in unallowable costs.Recommendation: We recommend that a member of the payroll department or fiscal team review each employee?s payroll/status change notice and compare to what is in the payroll system to ensure they agree.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2022-002: Represents a significant deficiency in internal control over compliance with Tallatoona Community Action Partnership, Inc.?s major federal programs.Repeat Finding: NoType of Finding: Material WeaknessDescription: Internal Control over Payroll ExpendituresMajor Programs: AL#93.569 ? Community Services Block Grant (Passed Through the Georgia Department of Human Services) and AL#93.600 ? Head Start Cluster (Direct)Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost PrinciplesAwards effected:CSBG 42700-040-0000096839 and CSBG 42700-040-0000103931COVID-19 CSBG 42700-040-0000103959 and COVID-19 CSBG 42700-040-0000095979Head Start FY-21 04CH010523-04-01 and Head Start FY-22 04CH010523-05-02COVID-19 Head Start ? CARES - FY21-FY23 04HE000247-01-01COVID-19 Head Start ? ARPA ? FY21-FY 23 04HE000247-01-01Early Head Start CCP FY 21 04HP000305-02-01 and Early Head Start CCP FY 22 04HP000305-03-00COVID-19 Early Head Start CCP CARES ? FY 21-FY 23 04HE000247-01-01COVID-19 Early Head Start CCP ARPA ? FY 21-FY 23 04HE000247-01-01View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) 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. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College 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 College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.