Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
2022-001 - Allowable Costs/Cost Principles Federal Program Information: Department of Education: ALN - 84.425D - Education Stabilization Fund Criteria: The following CFR(s) apply to this finding: 2 CFR 200.430(i)(1(vii) Condition: During audit procedures, it was identified that the School Department certifications for time and effort records were missing or incomplete. Cause: The School Department does not have the necessary internal controls over compliance. Effect: The School Department is not obtaining the required employee certifications that 100% of their time was spent on the grant cost objective ensuring that charges to the program reflect an accurate account of the employee?s time and effort devoted to the program. Identification of Questioned Costs: None identified. Context: The School Department does not collect time certifications for the employees that were paid with the federal funds. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the School Department implement internal control processes and procedures to ensure that time certifications are completed at the period end to ensure charges reflect an accurate account of the employee?s time devoted to the program. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the School Department.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022 - 002 / 50000 U.S. Department of Education - Passed through California Department of Education Title I Part A ALN 84.010 2021-22 TITLE I SCHOOLWIDE PROGRAMS Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: ? The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); ? The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); ? The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: The SPSA did not include the proposed expenditure of funds, allocated to the schools through the consolidated application, to address the findings identified in needs assessment. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wellington M. Smith, Jr. School and Salinas Community School. Effect: The County Office did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The County Office did not review the SPSA prepared by the school sites to ensure that it complied with Federal and State requirements. Recommendation: The County Office should review the Federal and State guidelines for preparing and documenting activities/expenditures in the SPSA. County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. There were 4 of 53 disbursements charged to the grant fund that were not in compliance with the Allowable Costs/Cost Principles compliance requirement. The 4 issues identified were as follows: 1. The School Corporation paid one employee's salary without supporting documentation or personnel reports, such as time and effort logs to support the time charged to the grant. 2. The School Corporation paid three employees a rate of pay not supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 32 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-010. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. There were 4 of 53 disbursements charged to the grant fund that were not in compliance with the Allowable Costs/Cost Principles compliance requirement. The 4 issues identified were as follows: 1. The School Corporation paid one employee's salary without supporting documentation or personnel reports, such as time and effort logs to support the time charged to the grant. 2. The School Corporation paid three employees a rate of pay not supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 32 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234
Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. 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 more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. 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 more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. 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 more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. 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 more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. 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 more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
Finding No. 2022-004 Allowable Costs/Cost Principles for Payroll Federal Program ALN 93.556 Promoting Safe and Stable Families Name of Federal Agency U.S. Department of Health and Human Services Pass-through Entity The Families and Children Administration of the Department of Family of the Commonwealth of Puerto Rico Category Significant deficiency of internal controls over compliance Criteria Section 200.405 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) indicates that a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. This standard is met, among other things, if the cost charged is incurred specifically for the federal award. Also, under cost principles established by 2 CFR Section 200.430, 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 and be incorporated into the official records of the non-Federal entity. Condition found For the period that covers October 1, 2021, to January 31, 2022, two employees approved time and attendance reports did not agree with what was reflected within the payroll system and therefore petitioned to the federal program. Time charged to the federal program was not based on actual hours. Cause Resignation of the personnel in charge of reconciling expenses to amounts charged to expense and billed to the program and a significant delay in replacing the personnel to continue the process of reconciliation on a timely basis. Effect The amount charged to the federal program and paid to the employees exceeded compensation contracted with the employees. If the compensation costs allocated to the grant cannot be supported in accordance with the Uniform Guidance, the granting agency could determine that these costs are not allowable. Such condition may cause the federal grantor to issue warnings and/or impose penalties to the University. Questioned cost Known questioned cost amounts to $1,934. Context As part of our compliance tests with allowable costs and cost principles, we selected forty-three (43) expense transactions of the Promoting Safe and Stable Families program amounting to $760,673, of which ten (10) items amounting to $51,998 were related to payroll paid under the program. Our test disclosed two (2) instances where the employee's hours worked on the program differed from the amount charged for the period examined. Amount petitioned to the program for the period under evaluation between the two employees amounted to $16,107. The actual amount per approved time sheets amounted to $14,173, leaving a difference of $1,934 between the two employees. The payroll population for the test amounted to $930,169. The projected difference amounts to $34,596 when known questioned costs of $1,934 (3.72% of the payroll sample) are projected to total payroll and benefits expended for the program. Identification of a repeat finding This is a repeat finding from the inmediate previous audit, finding no. 2021-007. Recommendation The University's program staff and management should ensure that the amounts charged to the federal award and disbursed to the employees are accurate and under the correct contract rates. Monthly reconciliation of all expenses, including of salaries charged to program versus actual hours incurred must be timely performed. Views of responsible officials and planned corrective actions The University?s management agrees with this finding. Please refer to the corrective action plan on pages 58-61.
Section III - Federal Award Findings and Questioned Costs 2022-101: Significant Deficiency in Internal Controls Over Compliance: Payroll FAL No. and Name: FAL 84.425C COVID-19: Governor's Emergency Education Relief (GEER) Funds Award Number: None Federal Agency: US Department of Education Compliance Requirement: Allowable Costs Questioned Costs: None Criteria: In accordance with 2 CFR, ?200.430(i)(1)(i), the Organization should maintain records that are supported by a system of internal control which provides reasonable assurance that the charges are accurate. Condition and context: We noted the following errors out of a sample of forty payroll transactions that we tested for the payroll period ended August 20, 2021: 1) one employee was not credited for an approved pay increase, 2) one employee was not paid for 4 hours included on the timesheet as hours worked, and 3) one employee was paid for 40 hours that was not documented on a timesheet or otherwise supported by an approved time off request. Cause: Documentation was not sufficient to support all amounts paid to employees and internal controls were not effective in preventing payroll errors. Effect: There is an increased risk that employee compensation will not be paid accurately and amounts charged to federal programs will not be properly supported. Recommendation: To help ensure that charges to payroll expenses are properly supported and accurate, the Organization should implement internal control policies and procedures that requires periodic reviews of employee records as it relates to payrates, amounts recorded on timesheets, and time off approvals. Management's Corrective Action Plan is included at the end of this report.
2022-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing No. 84.425U Criteria: Salaries and wages charged to Federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart I, 2 CFR ?200.430. Condition: Subpart I, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?Federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart I, 2 CFR ?200.430. Cause: The employee that was responsible for assisting and maintaining the records that accurately reflect the work performed, as described in Subpart I, 2 CFR ?200.430, to support salaries charged to Federal awards, left the District, and these forms had not been prepared since there was no replacement for the employee during the year. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the Federal award. Questioned Costs: None reported. Context: Total population size of payroll was 91. Audit sample size was 15% of population, which totaled 14, haphazardly selected for audit testing. The finding was identified on 3 out of the 14 samples tested. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to Federal awards in accordance with the requirements of the Uniform Guidance at Subpart I, 2 CFR ?200.430 Views of Responsible Officials of Auditee: The District replaced the employee that left the District, and the new employee is being trained on ensuring the appropriate documentation will be prepared to support the compliance with Subpart I, 2 CFR ?200.430.
FINDING 2022-004 - ALLOWABLE PAYROLL COSTS AND CONTROLS OVER PAYROLL (REPEAT) - HEAD START CLUSTER, FEDERAL ASSISTANCE LISTING NUMBER 93.600 Criteria: Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These charges must be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Records must support the distribution of the employee?s salary or wages among the specific activities or cost objectives, if the employee works on more than one federal award. 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses. Condition: The Organization?s payroll records did not accurately reflect the actual hours worked by employees whose salaries and wages were charged to the various direct and indirect cost centers for fiscal year 2022. We tested five pay periods and identified a lack of time studies performed in each pay period to support the budgeted percentages used to allocate an employee?s payroll to more than one cost center. Questioned Costs: $80,277 - Payroll and payroll tax expenses totaling $445,531 and $32,971, respectively, were charged to the Early Head Start federal award during fiscal year 2022 and subject to sampling. Our testing identified $74,862 and $5,415 of payroll and payroll tax expenses, respectively, of questioned costs. Our sample was a statistically valid sample. Effect: The current methodology of allocating payroll amongst the various programs and supporting cost centers could result in over allocating payroll costs to certain awards and other cost centers and allocating too little payroll costs to others. Cause: The Organization allocates payroll based on budgeted percentages, however, budget estimates alone do not qualify as support for charges to federal awards. Recommendation: The Organization should establish policies and procedures to support a system of internal controls, which provides a reasonable assurance that the charges to federal awards for salaries and other payroll related costs are accurate, allowable, and properly allocated. Documentation of all employees? approved pay rates, hours worked, and support for the allocation percentages (or actual hours worked) should be maintained. Management's Response: The Organization terminated our professional relationship with our financial services provider in FY23, Quatrro BSS. We established a financial services contract with Metropolitan Family Services (MFS) that began July 1, 2022. MFS manages over 130 million dollars in revenue each year and the current finance team has over 50+ years of combined experience managing government and private contracts. MFS is a Professional Employer Organization (PEO) for five organizations averaging four million dollars in annual revenue and has established back-office and finance service contracts with those organizations. MFS has policies and procedures to support a system of internal controls which provides a reasonable assurance that charges to federal awards for payroll related costs are accurate, allowable, and properly allocated. Budget estimates are used for interim accounting purposes provided the estimates produce reasonable approximations of activity performed. The MFS finance team and the Organization's executive team review payroll allocations each quarter. Allocations are supported by an after-the-fact accounting of employee time and effort in a Personal Activity Report (PAR), significant changes in work activity are identified and entered into the record, and the after-the-fact review is completed to make all necessary adjustments to the final amount charged to the Organization's federal awards to help ensure charges are accurate, allowable, and properly allocated.
FINDING 2022-004 - ALLOWABLE PAYROLL COSTS AND CONTROLS OVER PAYROLL (REPEAT) - HEAD START CLUSTER, FEDERAL ASSISTANCE LISTING NUMBER 93.600 Criteria: Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These charges must be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Records must support the distribution of the employee?s salary or wages among the specific activities or cost objectives, if the employee works on more than one federal award. 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses. Condition: The Organization?s payroll records did not accurately reflect the actual hours worked by employees whose salaries and wages were charged to the various direct and indirect cost centers for fiscal year 2022. We tested five pay periods and identified a lack of time studies performed in each pay period to support the budgeted percentages used to allocate an employee?s payroll to more than one cost center. Questioned Costs: $80,277 - Payroll and payroll tax expenses totaling $445,531 and $32,971, respectively, were charged to the Early Head Start federal award during fiscal year 2022 and subject to sampling. Our testing identified $74,862 and $5,415 of payroll and payroll tax expenses, respectively, of questioned costs. Our sample was a statistically valid sample. Effect: The current methodology of allocating payroll amongst the various programs and supporting cost centers could result in over allocating payroll costs to certain awards and other cost centers and allocating too little payroll costs to others. Cause: The Organization allocates payroll based on budgeted percentages, however, budget estimates alone do not qualify as support for charges to federal awards. Recommendation: The Organization should establish policies and procedures to support a system of internal controls, which provides a reasonable assurance that the charges to federal awards for salaries and other payroll related costs are accurate, allowable, and properly allocated. Documentation of all employees? approved pay rates, hours worked, and support for the allocation percentages (or actual hours worked) should be maintained. Management's Response: The Organization terminated our professional relationship with our financial services provider in FY23, Quatrro BSS. We established a financial services contract with Metropolitan Family Services (MFS) that began July 1, 2022. MFS manages over 130 million dollars in revenue each year and the current finance team has over 50+ years of combined experience managing government and private contracts. MFS is a Professional Employer Organization (PEO) for five organizations averaging four million dollars in annual revenue and has established back-office and finance service contracts with those organizations. MFS has policies and procedures to support a system of internal controls which provides a reasonable assurance that charges to federal awards for payroll related costs are accurate, allowable, and properly allocated. Budget estimates are used for interim accounting purposes provided the estimates produce reasonable approximations of activity performed. The MFS finance team and the Organization's executive team review payroll allocations each quarter. Allocations are supported by an after-the-fact accounting of employee time and effort in a Personal Activity Report (PAR), significant changes in work activity are identified and entered into the record, and the after-the-fact review is completed to make all necessary adjustments to the final amount charged to the Organization's federal awards to help ensure charges are accurate, allowable, and properly allocated.
2022-001: Residential Treatment Services ? Allowable Costs Federal Agency: Department of Health and Human Services CFDA No.: 93.959 Federal Program: Block Grants for Prevention and Treatment of Substance Abuse Federal Award Program No.: H2810DEZ and H2810DFZ Federal Award Year: 2022 Control Category: Allowable Costs Questioned Costs: $0.00 Criteria: 2 CFR 200.430, Compensation ? personal services, states, in part: ?(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: During our review of payroll costs for the year ended June 30, 2022, we noted four instances where the employee did not have a personnel action form to document the change in their pay grade for the pay period tested. Other employees did not have an initial personnel action form to show the pay grade at the time of hire. Cause: Hope House management noted that not completing initial documentation at the employee?s hire date caused a deficiency in maintaining supporting documentation for merit increases. Effect: We were unable to determine if the amount paid to the employee was approved by management. Questioned Costs: $0.00 Recommendation: We recommend that Hope House prepare and maintain a copy of each employee's initial compensation and merit increase.
Criteria: Per federal regulations 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort distribution records for an employee who works, all or in part, under federal grants. Condition: The School District did not maintain proper time and effort records for employees who were partially funded with ESSER federal funds. Timesheets did not contain a certification clause that the information submitted accurately reflects the time and effort distribution, and the timesheet was not dated by the employee and/or supervisor. Cause: The School District was not aware of the required detail. Effect: The School District was not in compliance with all of the components of the requirements. Recommendation: We recommend that the School District ensure that all timesheets include the related employee data, clearly identified time segregated between federal and non-federal funding, and a properly signed time and effort certification statement.
FINDING 2022-003 DYER COUNTY SCHOOL DEPARTMENT HAD DEFICIENCIES IN THE USE OF EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) GRANT FUNDS, WHICH RESULTED IN QUESTIONED COSTS (A. ? Noncompliance Under Government Auditing Standards and OMB Uniform Guidance; B. - Internal Control ? Significant Deficiency Under Government Auditing Standards and OMB Uniform Guidance) Entity Dyer County, Tennessee ? School Department Repeat Finding Number N/A Assistance Listings # 93.323 Assistance Listings Title Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Agency Department of Health and Human Services State Pass-Through Agency Department of Education Grant/Contract No. N/A Federal Award Year 2022 Finding Type Noncompliance and Internal Control ? 93.323 Compliance Requirement Allowable Cost/Cost Principles Known Questioned Costs $63,589 The school department was awarded an Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (FAL No. 93.323) made available from the American Rescue Plan Act of 2021, passed through the Tennessee Department of Education. We audited the ELC grant as a major federal program in compliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). As part of our audit procedures, we tested a sample of 32 disbursement items for the period July 1, 2021, through June 30, 2022. Based on our test work, we noted the following deficiencies, which are the result of a lack of management oversight: A. On July 26, 2021, the following administrative staff received bonuses paid with ELC funds as direct grant costs: Director of Schools $27,688; Business and Finance Manager $11,886; Special Education Director $8,037; Federal Projects Bookkeeper $4,126 Federal Projects Bookkeeper (former) $4,126; Payroll Bookkeeper $3,863; Accounts Payable/Receivable Bookkeeper $3,863; for a total of $63,589. Section 200.413 of the Uniform Guidance provides that administrative and clerical staff should normally be treated as indirect costs; however, direct charging of these costs may be appropriate only if all of the following conditions are met: 1. Administrative or clerical services are integral to a project or activity; 2. Individuals involved can be specifically identified with the project or activity; 3. Such costs are explicitly included in the budget or have prior written approval of the federal awarding agency; and 4. The costs are not recovered as indirect costs. We were not provided with adequate documentation to support these payments as direct costs. The services provided by the administrative staff do not appear to be integral to the ELC grant; the individuals were not specifically identified to the project; and the bonuses were not explicitly included in the budget, nor did they have prior written approval of the federal awarding agency. At the time the bonuses were paid, the ELC grant documentation listed the following as allowable direct uses of funds: salaries, benefits, and contract costs of nurses; travel reimbursed at .47 per mile; contracts with academic institutions, private laboratories, or other healthcare entities to process test kits; supplies and equipment for testing; minor construction for safer testing locations; costs associated with operating alternate/pop-up sites; costs for running mass testing programs; and shipping, postage, printing, and duplicating costs. Updated guidance for the ELC grant was issued on August 2, 2021. Per the updated guidance, when determining allowable costs, grant recipients were referred to the cost principles regulation found in 45 CFR Part 75 Subpart E ? Cost Principles which states that allowable costs should be necessary and reasonable for the performance of the federal award, be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the entity, and be adequately documented. It further states that costs are reasonable if they do not exceed that which would be incurred by a prudent person under the circumstance. These bonuses do not appear to be reasonable and necessary for the performance of the award, are not consistent with other grants and programs of the school system and were not properly documented. B. Duties were not adequately segregated concerning the bonus payments associated with ELC grant funds. The bonuses paid to the administrative staff were not specifically approved by the grantor or the board of education. The board of education did approve a budget amendment on February 1, 2022, allowing bonuses under this grant program totaling $141,519, which included $62,295 for nurses and transportation and maintenance staff; however, the board of education was not given a breakdown of who received a bonus and the individual amounts. It should be noted that the current chairman of the board of education advised that he was unaware the director of schools received amounts in excess of her contract. As a result, the director of schools authorized a bonus payment to herself without prior approval of the board of education. As a result of the deficiencies noted above, we have questioned the cost of the bonuses for administrative staff totaling $63,589 for the period July 1, 2021, through June 30, 2022. RECOMMENDATION The board of education should determine the propriety and reasonableness of the bonus payments paid to the administrative staff from ELC funds. The board should take steps to resolve the questioned costs. Duties should be properly segregated. The director of schools should not approve her own bonus payments. MANAGEMENT?S RESPONSE ? DIRECTOR OF SCHOOLS We disagree with this finding. With regard to the matters referenced in section A of the draft finding, we take issue with the allegations that the bonuses paid to the administrative staff were not explicitly included in the grant budget, the individuals receiving the bonuses were not identified to the grantor and the grantor did not approve of the bonus payments, all of which are absolutely false. Section 200.407 of the Uniform Guidance provides: "Under any given Federal award, the reasonableness and allocability of certain items of costs may be difficult to determine. In order to avoid subsequent disallowance or dispute based on unreasonableness or nonallocability, the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs." On June 14, 2021, the Dyer County School's ELC grant application was approved by the grantor in the amount of $1,021,466.91. The approved budget for the grant expressly included bonus payments in the amount of $63,589.14 to the Administrators, Director, and other related personnel for duties and responsibilities related to the implementation and administration of the COVID Testing program. See Exhibit A, approved grant budget for Account Number: 72130-Other Student Support, Line-Item Number: 188-Bonus Payments in the amount of $63,589.14. Not only were the administrative bonus payments specifically approved by the grantor in the budget, but the grantor was also provided with the names and exact amounts paid to each member of the administrative staff when the system requested and thereafter received reimbursement from the grantor for those payments. See Exhibit B, Statement of Expenditures and Encumbrances dated August 30, 2021, which was submitted to the grantor. When your office first raised this issue, we immediately confirmed that it was proper for ELC grant funds to be used to pay bonuses to the administrative staff for duties and responsibilities related to the implementation and administration of the program. See Exhibit C, email to Wendy Smith, Business and Finance Manager for the school system, dated August 29, 2022, from Kristi Steele, Director of Mental Health, Tennessee Department of Education, which provides: ?ELC funding can be used to pay stipends/salaries for individuals such as coordinated school health coordinators, district level administrators, etc. who manage the grant and who have been handling COVID response to their districts.? Your staff auditor, who was copied on the email from Ms. Steel, then asserted that the administrative staff was required under the grant to keep timesheets documenting the time spent related to the implementation and administration of COVID response for the school system. Exhibit D is an email dated August 30, 2022, from Jennifer Sanchez, Public Health Administrator II (Project Manager), Tennessee Department of Health, confirming the timesheets were not, in fact, a requirement for the payment of bonuses under the grant. Moreover, Maryanne Durksi, Executive Director, Office of Local Finance, Tennessee Department of Education has advised: ?the approved application in ePlan, with the stipends clearly in the narrative, should be documentation that these were approved by the state.? As a result of the foregoing, we believe the allegations in section A of the draft audit finding are without merit and should be removed from your final audit. With regards to the matters in section B of the draft finding, we take issue with the allegations that the bonuses paid to the administrative staff for the extra duties and responsibilities related to the implementation and administration of the ELC grant were not approved by the grantor or the board of education. The grantor's approval of the payments to the administrative staff in connection with the grant was discussed above and such will not be repeated again. We agree with you that Mr. Jeremy Gatlin, the current chairman of the board of education, has advised that he was not aware that the Director was one of the individuals who received bonus payments under the grant, but we find it curious that your draft finding does not also mention the very relevant additional information provided to your office by Mr. Keith Anderson, who was the chairman of the board of education at the time the ELC application was submitted, approved by the state and payments made to the administrative staff. See Exhibit E, statement of Keith Anderson, confirming that in May of 2021 he had a telephone conversation with Mrs. Wendy Smith regarding the grant application, that he was aware of and gave his approval regarding the employees eligible to receive a stipend due to extra duties associated with the COVID response program, including, but not limited to, the administrative, financial staff and the Director of Schools, the amounts of stipend each would receive in each group, and the percentages of salaries the stipend would equal. As you noted, the board of education approved the budget amendment regarding the ELC Grant on February 1, 2022. The budget amendment accurately reflects that the stipends paid under the grant to the administrative staff was transferred to the proper accounts, as approved in the grant budget, account 72130, line item 188 ? Other Student Support. We agree with you that the board of education was not provided a breakdown of who received a bonus and the individual amounts at the time the budget amendment was adopted. Any future bonus payments to members of the administrative staff will be approved by the board prior to disbursement to ensure that duties are? adequately segregated. We believe the methodology used for determining the amount of bonus payments to each group of employees/SROs involved with the implementation and management of the COVID response program and the allocation of such funds among the various individuals based on their program responsibilities was reasonable, but we defer to the board of education's response, set forth below, to address your recommendation that the board determine the propriety and reasonableness of the bonus payments paid to the administrative staff from ELC funds. MANAGEMENT?S RESPONSE ? DR. JEREMY GATLIN, BOARD OF EDUCATION CHAIRMAN The board disagrees with this finding. The board agrees with the response provided by the Director, as set forth above. The board believes it was appropriate to utilize a portion of the ELC grant funds to provide bonus payments to the administrative staff for the additional duties and responsibilities required to manage and administer the COVID response program for the benefit of approximately 4,000 students and employees of the school system over the term of the grant. Section 200.430(6) of the Uniform Guidelines provides: Reasonableness. Compensation for employees engaged in work on Federal awards will be considered reasonable to the extent that it is consistent with that paid for similar work in other activities of the non-Federal entity. The bonus payments provided to the members of the administrative staff to manage the COVID response program were reasonable because the payments were determined based on the additional program responsibilities required of each of them in a manner that is consistent with the amounts paid to them for similar work in other activities on behalf of the school system. Going forward, any bonus payments provided to members of the administrative staff will be approved by the board before the funds are disbursed to ensure that duties are adequately segregated. AUDITOR?S COMMENT The budget for the ELC grant submitted to the Tennessee Department of Education did include $63,589 budgeted to Other Student Support ? Bonus Payments; however, the narrative description stated that it included ?SRO?s, Administrators, Director, and other related personnel.? There were no SRO?s paid from this line-item, and the director of schools was not specifically mentioned. Director in this instance could have implied the director of the program administering the grant. The only personnel paid from this budget line were the director of schools and six other administrative staff members. The narrative appears misleading and would not be sufficient to give prior explicit approval for these types of bonuses. The response of the director of schools? quotes Section 200.407 of the Uniform Guidance which provides: " ? the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs." It should be noted the budget submitted for bonus payments was made to the Tennessee Department of Education which is a non-federal entity. The Federal awarding agency for this award is the U.S. Department of Education. Regardless of the matter of whether or was not there was proper approval to pay bonuses, there still must be proper documentation to support that the person was actually entitled to receive the bonus. Uniform Guidance Section 200.430(i) states ?Standards of 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 include: ? (vii) Support the distribution of the employee?s salary or wage among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and a non-federal award, an indirect cost activity and a direct cost activity, two or more indirect activities??. The school department has not provided us with any documented evidence to support that these individuals performed any work on this federal award. Without any supporting documentation of actual work performed on the grant by these individuals, we cannot attest these individuals were entitled to receive a bonus. Auditors were told by the former chairman of the Board of Education that he gave verbal approval of the bonuses; however, without any written documentation, we cannot attest that this happened. Furthermore, the former chairman has no authority on his own to approve bonus payments. The Board of Education, as a whole, would need to vote in order to grant such approval. As mentioned in the finding, the board of education did approve a budget amendment on February 1, 2022. However, it is important to note that this amendment occurred approximately seven months after the bonuses were paid and makes no mention of bonuses being paid to anyone or the amounts these individuals received. The explanation of the amendment states, ?these funds will be used to reimburse a portion of General Purpose funds already budgeted for line items for? Administrative Financial Staff for salary associated with the responsibilities related to duties under the ELC Grant?? Therefore, from the evidence presented to us, it is not clear that the Board of Education, as a whole, even knew these bonuses were paid until reported in our finding and the budget amendment itself does not provide adequate support for the proper approval of these payments as bonuses. The response of the Board of Education references Section 200.430(b) of the Uniform Guidelines provides: Reasonableness. Compensation for employees engaged in work on Federal awards will be considered reasonable to the extent that it is consistent with that paid for similar work in other activities of the non-Federal entity. While bonuses paid with local funds typically do not require a timesheet, Section 200.430(i) states ?Standards of Documentation of Personnel Expenses. (1) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed...?, In order for us to determine if these bonuses were reasonable and allowable, there must be documented proof that the administrative personnel receiving the bonuses actually devoted their time to administering the grant. We have not been presented with any documented evidence that the administrative staff spent any time on this grant. Furthermore, these administrative staff members were not paid bonuses for any of the hours they devoted to the other federal grants received by the school department. Therefore, the paying of bonuses associated with the ELC grant was inconsistent with the other grants received by the Board of Education. Additionally, the director of schools is employed through a contract between the director of schools and the board of education for the period January 5, 2021, through June 30, 2023, which states that the duties of the director of schools will generally be performed during normal business hours, but it is expressly agreed that the duties will require her to work during times other than normal business hours. The contract makes no mention of bonuses, and it appears anything beyond normal business hours is already included in her contract amount. Therefore, it is questionable if the director?s contract allows for the payment of a bonus.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.
Finding Number: 2022-003 Program: Research and Development Cluster Federal Agency Name: Various Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Numbers: Various Criteria The Uniform Guidance Section 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testing of payroll allowability we noted 4 out of 71 payroll transactions tested were paid and charged to the grant incorrectly. Additionally, for 3 out of 71 payroll transactions the amount allocated to the grant was incorrect. The incorrect payments and allocations to grants were due to manual errors when processing payroll and related after the fact allocations to federal grants. We deemed this to be a material weakness in internal controls and noncompiance with the allowable costs compliance requirement. Our sample was not, and was not intended to be statistically valid. This finding is a repeat finding in the immediately prior audit finding 2021-003 Questioned Costs Unallowable payroll costs charged to the grants below FALN 12.300 $ 170 FALN 12.300 170 FALN 47.041 5,744 FALN 47.076 7 Total $ 6,091 Cause Manual calculations or clerical errors of the amount to be paid/and or allocated to the grant were made before being entered into the system. There was no secondary review of the calculation by someone other than the preparer.The University did not have an adequately designed internal control to identify calculation errors in applying payroll amounts to federal awards and as such, the amount of the errors and related non-compliance could have been greater and not detected by the University?s control environment. Effect Payroll amounts charged to federal grants are unsupported by actual time spent on the award and are thus unallowable. Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to review payroll authorization forms and manual calculations performed before the payroll allocation is recorded to the federal grant.